Estate of Camara v. Commissioner
United States Tax Court
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
- McManus v. CommissionerUnited States Tax Court · 1975
- Norman B. Tapper and Eileen Tapper v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
- Grunwald v. CommissionerUnited States Tax Court · 1986
- Greylock Mills v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1929
- 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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