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KOVENS v. COMMISSIONER

Docket No. 5435-82.

90 T.C. 452 (1988)

CALVIN KOVENS AND ROZ M. KOVENS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 17, 1988.

Attorney(s) appearing for the Case

Harvey M. Silets, Steven S. Brown, and Royal B. Martin, Jr., for the petitioners.

Thomas R. Ascher, for the respondent.

GERBER, Judge:

The parties in this case requested us to consider a bifurcated procedural issue concerning the statute of limitations which would be dispositive of the taxable years in issue if decided in petitioners' favor.1 The issue concerns interpretation of the Form 872-A agreement to extend the period within which respondent can assess and collect tax. Petitioners contend that respondent "breached" the terms of the Form 872...

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