Kronish v. Commissioner
United States Tax Court
While F, P's attorney, was away on vacation, P signed a Form 872, entitled "Consent to Extend the Time to Assess Tax," that purported to extend the period of limitations on assessment with respect to P's taxable year 1978. At the time P signed the form, she believed that the form's terms conformed with the terms F desired. In fact, the form's terms did not conform with the terms F desired.
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While F, P's attorney, was away on vacation, P signed a Form 872, entitled "Consent to Extend the Time to Assess Tax," that purported to extend the period of limitations on assessment with respect to P's taxable year 1978. At the time P signed the form, she believed that the form's terms conformed with the terms F desired. In fact, the form's terms did not conform with the terms F desired. Subsequently, R sought to have P sign another Form 872 with respect to P's taxable year 1978. The second Form 872 contained the same terms as the first Form 872, except that it purported to further extend…
1Opinion of the Court
Peggy J. Kronish, Petitioner v. Commissioner of Internal Revenue, Respondent
Kronish v. Commissioner
Docket No. 32574-84
United States Tax Court
90 T.C. 684; 1988 U.S. Tax Ct. LEXIS 43; 90 T.C. No. 42;
April 13, 1988; As amended April 14, 1988 April 13, 1988, Filed
Decision will be entered for the respondent.
While F, P's attorney, was away on vacation, P signed a Form 872, entitled "Consent to Extend the Time to Assess Tax," that purported to extend the period of limitations on assessment with respect to P's taxable year 1978. At the time P signed the form, she believed that the form's terms…
2Cases cited20 opinions
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Pimpinello v. Swift & Co.New York Court of Appeals · 1930
- Stange v. United StatesSupreme Court of the United States · 1931
- Estate of Emerson v. CommissionerUnited States Tax Court · 1977
- Samuel Pollack and Annie Pollack v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
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