Legal Opinion
William A. Kernen, Betty A. Kernen v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided May 3, 1990No. 89-70093PublishedCited by 12 opinions
1Per curiam
In connection with their 1977 tax return, William and Betty Kernen executed three forms extending the limitations period for assessment of deficiencies by the IRS. In November 1980, the Kernens executed a Form 872, which extended the limitations period to December 31, 1981. In December 1980, the Kernens executed a Form 872-A, which extended indefinitely the limitations period for adjustments by the IRS. Finally, in May 1981, the Kernens signed a second Form 872, which provided for extension of the limitations period until April 30, 1983.
On September 9, 1986, the Commissioner issued to the…
2Cases cited3 opinions
- Norman B. Tapper and Eileen Tapper v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- William H. Kinsey, and Estate of Irene S. Kinsey, Deceased, William H. Kinsey v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Podell v. CommissionerUnited States Tax Court · 1987
3Cited by12 opinions
- Barry I. Fredericks v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1997
- DeSantis v. United StatesDistrict Court, S.D. New York · 1992
- Federal National Mortgage Association v. United StatesCourt of Appeals for the Federal Circuit · 2006
- Estate of Carberry v. CommissionerUnited States Tax Court · 1990
- Robert M. St. John, Margaret E. St. John v. United States of America, Robert M. St. John, Margaret E. St. John v. United StatesCourt of Appeals for the Ninth Circuit · 1991
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