Rault v. Commissioner
United States Tax Court
After petitioners had signed numerous Forms 872 extending the statute of limitations, petitioners executed Forms 872-A extending the statute until 90 days after a written notification of termination of the consent to the extension was received by respondent from petitioners.
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After petitioners had signed numerous Forms 872 extending the statute of limitations, petitioners executed Forms 872-A extending the statute until 90 days after a written notification of termination of the consent to the extension was received by respondent from petitioners. By letter dated October 28, 1975, petitioners' counsel indicated to an Appeals Officer of the Internal Revenue Service that due to the impasse reached by the parties in the Appellate Division of the Internal Revenue Service he was requesting the issuance of notices of deficiency. Held: The letter of October 28, 1975,…
1Opinion of the Court
JOSEPH M. RAULT, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; RAULT PETROLEUM CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Rault v. Commissioner
Docket Nos. 5901-77, 5905-77.
United States Tax Court
T.C. Memo 1982-283; 1982 Tax Ct. Memo LEXIS 457; 43 T.C.M. (CCH) 1446; T.C.M. (RIA) 82283;
May 24, 1982.
After petitioners had signed numerous Forms 872 extending the statute of limitations, petitioners executed Forms 872-A extending the statute until 90 days after a written notification of termination of the consent to the extension was received by…
2Cases cited12 opinions
- Robinson v. CommissionerUnited States Tax Court · 1972
- McManus v. CommissionerUnited States Tax Court · 1975
- Concrete Engineering Co. v. Commissioner of Int. Rev.Court of Appeals for the Eighth Circuit · 1932
- Farmers Feed Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Ventura Consolidated Oil Fields v. RoganCourt of Appeals for the Ninth Circuit · 1936
7 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- J.H. Rutter Rex Mfg. Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Myers v. CommissionerUnited States Tax Court · 1988