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JACOBS v. COMMISSIONER

Docket No. 25551-85.

55 T.C.M. 96 (1988)

T.C. Memo. 1988-52

Raymond Jacobs and Eleanor Jacobs v. Commissioner.

United States Tax Court.

Filed February 18, 1988.

Attorney(s) appearing for the Case

Stephen J. Saft, 2425 Post Rd., Southport, Conn., and Thomas Minogue (specially recognized), for the petitioners. Robert E. Marum, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for the years 1974 and 1975 of $76,173 and $237,014, respectively. After concessions, the sole issue for decision is whether consent forms extending the period of the statute of limitations for petitioners' tax years 1974 and 1975 were valid.

Consent forms, Form 872 (Consent Fixing Period of Limitation Upon Assessment of Tax...

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