Coffey v. Commissioner
United States Tax Court
P and R entered into a Form 872-A agreement to extend the period for assessment. The agreement terminated upon R's mailing a notice of deficiency or upon a final assessment being made. R sent a misaddressed notice of deficiency to P and assessed the tax after P failed to timely petition this Court. P then filed an untimely petition which was dismissed on P's motion with R's consent. R proceeded to send a properly addressed second notice from which P timely petitioned.
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P and R entered into a Form 872-A agreement to extend the period for assessment. The agreement terminated upon R's mailing a notice of deficiency or upon a final assessment being made. R sent a misaddressed notice of deficiency to P and assessed the tax after P failed to timely petition this Court. P then filed an untimely petition which was dismissed on P's motion with R's consent. R proceeded to send a properly addressed second notice from which P timely petitioned. P then moved for summary judgment contending that the Form 872-A agreement had been terminated under the holding of Roszkos v.…
1Opinion of the Court
Donald R. Coffey and Janis I. Coffey, Petitioners v. Commissioner of Internal Revenue, Respondent
Coffey v. Commissioner
Docket No. 11846-87
United States Tax Court
96 T.C. 161; 1991 U.S. Tax Ct. LEXIS 7; 96 T.C. No. 7;
January 28, 1991, Filed
P and R entered into a Form 872-A agreement to extend the period for assessment. The agreement terminated upon R's mailing a notice of deficiency or upon a final assessment being made. R sent a misaddressed notice of deficiency to P and assessed the tax after P failed to timely petition this Court. P then filed an untimely petition which was dismissed on P's…
2Cases cited5 opinions
- Louis E. Roszkos and Vivian L. Roszkos v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Roszkos v. CommissionerUnited States Tax Court · 1986
- Harry Holof and Norma Holof v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1989
- Charles E. Hubbard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989
- Coffey v. CommissionerUnited States Tax Court · 1991