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
OPINION
TANNENWALD, Judge:
Respondent determined the following deficiencies in petitioners’ Federal income tax:
Year Deficiency
1971.$4,316.85
1973. 11,272.14 .
1974. 7,711.83.
1975. 17,127.85.
1976. 20,458.66
1977. 8,838.38
By order of the Court, issues relating to the years 1971, 1973, and 1976 were severed. The parties agree that the adjustments are proper and that the deficiencies are due unless assessment thereof is barred by the statute of limitations.
All of the facts have been stipulated. The stipulation of facts and attached exhibits are incorporated herein by this reference.
Billie J. Camara…
2Cases cited16 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
11 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Mecom v. CommissionerUnited States Tax Court · 1993
- Richard R. Stenclik and Dolores Stenclik v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1990
- Douglas E. Wall v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1989
- 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
13 more not listed; retrieve them via the Exa API.