Legal Opinion

Jordan v. Comm'r

United States Tax Court

Decided January 11, 2010No. 14572-07LPublished

P wife signed a Form 900, Tax Collection Waiver, containing a waiver extending the 10-year period of limitations on collection for the first 4 of the tax years in issue. After signing the waiver, Ps entered into an installment agreement with R. Although P husband's signature purportedly appears on the Form 900, P husband contends that he never signed the Form 900 and, therefore, the waiver is invalid as to both Ps.

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P wife signed a Form 900, Tax Collection Waiver, containing a waiver extending the 10-year period of limitations on collection for the first 4 of the tax years in issue. After signing the waiver, Ps entered into an installment agreement with R. Although P husband's signature purportedly appears on the Form 900, P husband contends that he never signed the Form 900 and, therefore, the waiver is invalid as to both Ps. R contends that P husband signed the waiver and that, if P husband did not sign the waiver, the waiver is nevertheless valid as to both Ps. Ps also contend that R failed to send Ps…

1Opinion of the Court

SHELBY L. JORDAN AND DONAZELLA H. JORDAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Jordan v. Comm'r

No. 14572-07L

United States Tax Court

134 T.C. 1; 2010 U.S. Tax Ct. LEXIS 1; 134 T.C. No. 1;

January 11, 2010, Filed

P wife signed a Form 900, Tax Collection Waiver, containing a waiver extending the 10-year period of limitations on collection for the first 4 of the tax years in issue. After signing the waiver, Ps entered into an installment agreement with R. Although P husband's signature purportedly appears on the Form 900, P husband contends that he never signed the Form 900…

2Cases cited23 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Goza v. CommissionerUnited States Tax Court · 2000
  3. Sego v. CommissionerUnited States Tax Court · 2000
  4. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  5. Murphy v. Commissioner of IRSCourt of Appeals for the First Circuit · 2006

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