Legal Opinion

Stenclik v. Commissioner

United States Tax Court

Decided January 11, 1989No. Docket Nos. 5895-85; 28295-87UnpublishedCited by 2 opinions

Forms 872-A were executed on behalf of petitioners and respondent for the years in issue. Held: Forms 872-A do not expire by operation of law after a reasonable time. Estate of Camara v. Commissioner,91 T.C. 957 (1988).

1Opinion of the Court

RICHARD R. STENCLIK AND DOLORES STENCLIK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Stenclik v. Commissioner

Docket Nos. 5895-85; 28295-87.

United States Tax Court

T.C. Memo 1989-19; 1989 Tax Ct. Memo LEXIS 19; 56 T.C.M. (CCH) 1059; T.C.M. (RIA) 89019;

January 11, 1989; As amended March 30, 1989

Forms 872-A were executed on behalf of petitioners and respondent for the years in issue. Held: Forms 872-A do not expire by operation of law after a reasonable time. Estate of Camara v. Commissioner,91 T.C. 957 (1988).

Basil Tzetzo, for the petitioners.

Jerome F. Warner [Text Deleted By…

2Cases cited4 opinions

  1. Naftel v. CommissionerUnited States Tax Court · 1985
  2. McManus v. CommissionerUnited States Tax Court · 1975
  3. Norman B. Tapper and Eileen Tapper v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
  4. Estate of Camara v. CommissionerUnited States Tax Court · 1988

3Cited by2 opinions

  1. Douglas E. Wall v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1989
  2. Masraff v. CommissionerUnited States Tax Court · 1989

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