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BUGABOO TIMBER CO. v. COMMISSIONER

Docket Nos. 13786-90, 22353-90.

101 T.C. 474 (1993)

BUGABOO TIMBER CO., GERTRUDE J. MORGAN, TAX MATTERS PERSON, AND VERNON R. MORGAN, ALLEGED TO BE ITS TAX MATTERS PERSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT DAVIDSON INDUSTRIES, INC., F.D. CROWELL, TAX MATTERS PERSON, AND D.L. DAVIDSON, ALLEGED TO BE ITS TAX MATTERS PERSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 22, 1993.

Attorney(s) appearing for the Case

Charles P. Duffy, Philip N. Jones, and Peter J. Duffy, for petitioners.

Cheryl B. Harris, for respondent.

FAY, Judge:

These cases were consolidated solely for purposes of our consideration of the procedural issue whether Forms 872-S, Consents to Extend the Time to Assess Tax Attributable to Items of an S Corporation, were signed by the tax matters person (TMP)1 of each entity or a person with written authorization to sign so that the period of limitations for assessment is open.

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