Hicks v. Commissioner
United States Tax Court
R mailed Ps a Form 872 (Consent to Extend the Time to Assess Tax) for the taxable year 1984 under the cover of a letter which stated that the audit would be limited to an examination of Ps' claimed Schedule E losses for a specific rental property. Ps' accountant reviewed the transmittal letter and advised Ps to execute the Form 872. Ps and their accountant executed the Form 872 which did not contain any language restricting the scope of the examination.
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R mailed Ps a Form 872 (Consent to Extend the Time to Assess Tax) for the taxable year 1984 under the cover of a letter which stated that the audit would be limited to an examination of Ps' claimed Schedule E losses for a specific rental property. Ps' accountant reviewed the transmittal letter and advised Ps to execute the Form 872. Ps and their accountant executed the Form 872 which did not contain any language restricting the scope of the examination. Held, the parties did not mutually agree as to the terms of the Form 872, and therefore it is invalid. Held further, the period of…
1Opinion of the Court
EDWARD S. AND GLORIA M. HICKS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hicks v. Commissioner
Docket No. 22076-89
United States Tax Court
T.C. Memo 1991-564; 1991 Tax Ct. Memo LEXIS 613; 62 T.C.M. (CCH) 1234; T.C.M. (RIA) 91564;
November 21, 1991, Filed
Decision will be entered under Rule 155.
R mailed Ps a Form 872 (Consent to Extend the Time to Assess Tax) for the taxable year 1984 under the cover of a letter which stated that the audit would be limited to an examination of Ps' claimed Schedule E losses for a specific rental property. Ps' accountant reviewed the transmittal…
2Cited by1 opinion
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