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NEUHOFF v. COMMISSIONER

Docket No. 9650-76.

75 T.C. 36 (1980)

ANN F. NEUHOFF, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 7, 1980.

Attorney(s) appearing for the Case

Jimmy L. Heisz and Neil J. O'Brien, for the petitioner.

Barry M. Bloom, for the respondent.

GOFFE, Judge:

The Commissioner determined deficiencies in petitioner's Federal income tax for the taxable years 1971 and 1972 in the respective amounts of $18,899.75 and $5,267.69.

The issues for our decision are:

(1) Whether the Consent Fixing Period of Limitation Upon Assessment of Income Tax (Form 872) signed by petitioner operated, under section 6501(c)(4), I.R.C. 1954,1 to prevent the period of limitations for...

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