Sidney L. Gaynes v. United States

The sole issue on this appeal is whether the taxpayer, Sidney L. Gaynes, validly executed a waiver of his right to contest the amount of his tax liability when he signed Form 870-AD. 1 Gaynes offers two reasons in support of his contention that the Form 870-AD was not validly executed. First, he says he was induced to sign the form through the misrepresentations of the responsible government agent. Second, Gaynes says that the waiver related to tax years for which he had filed a joint return, and that the signature of his wife at that time was required for valid execution of the waiver.

The…