Johnson v. Commissioner
United States Tax Court
Each petitioner executed an "unlimited waiver" (Form 872-A) for the taxable year 1965 which provided in part that the period of limitation for assessment of income taxes was extended to a date not more than 90 days after "mailing by the Internal Revenue Service of written notification to the Taxpayer(s) of termination of Appellate Division consideration."
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Each petitioner executed an "unlimited waiver" (Form 872-A) for the taxable year 1965 which provided in part that the period of limitation for assessment of income taxes was extended to a date not more than 90 days after "mailing by the Internal Revenue Service of written notification to the Taxpayer(s) of termination of Appellate Division consideration." Held, letters mailed by respondent's authorized agent to petitioners on Jan. 2, 1973, and Mar. 6, 1973, respectively, constituted the requisite notification of termination of Appellate Division consideration which triggered the running of…
1Opinion of the Court
OPINION
Dawson, Judge:
These two cases are before the Court on petitioners’ motions for summary judgment filed March 25, 1977, with respect to docket No. 7461-73, and April 11, 1977, with respect to docket No. 7718-73, pursuant to the provisions of Rule 121, Tax Court Rules of Practice and Procedure. Respondent filed objections to the motions on April 15, 1977, and a hearing was held in Washington, D.C., on April 27, 1977. Petitioners in each docket filed a memorandum at the hearing urging summary judgment in their favor. Respondent subsequently filed a memorandum in opposition on May 27, 1977,…
2Cited by20 opinions
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- Kovens v. CommissionerUnited States Tax Court · 1988
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