Legal Opinion

Estate of Camara v. Commissioner

United States Tax Court

Decided November 23, 1988No. Docket No. 32918-86Published

A series of Forms 872 was executed on behalf of petitioners and respondent for the years in issue. Subsequently, Forms 872-A were executed on behalf of petitioners and respondent. Held: Forms 872-A do not expire by operation of law after a reasonable time. To the extent that McManus v. Commissioner, 65 T.C. 197 (1975), affd. 583 F.2d 443 (9th Cir. 1978), requires a different result, we will no longer follow it.

1Opinion of the Court

Estate of Prudencio B. Camara, Deceased, David L. Ziegler, Executor, and Billie J. Camara, Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Camara v. Commissioner

Docket No. 32918-86

United States Tax Court

91 T.C. 957; 1988 U.S. Tax Ct. LEXIS 144; 91 T.C. No. 60;

November 23, 1988. November 23, 1988, Filed

Decision will be entered under Rule 155.

A series of Forms 872 was executed on behalf of petitioners and respondent for the years in issue. Subsequently, Forms 872-A were executed on behalf of petitioners and respondent. Held: Forms 872-A do not expire by operation of law…

2Cases cited17 opinions

  1. McManus v. CommissionerUnited States Tax Court · 1975
  2. Norman B. Tapper and Eileen Tapper v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
  3. Grunwald v. CommissionerUnited States Tax Court · 1986
  4. Greylock Mills v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1929
  5. E. H. Winn, Jr. And Betty Lee Jones Winn v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1979

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