ALLBRIGHT v. COMMISSIONER

Docket No. 20649-89.

59 T.C.M. 190 (1990)

T.C. Memo. 1990-154

Robert W. Allbright v. Commissioner.

United States Tax Court.

Filed March 22, 1990.


Attorney(s) appearing for the Case

Robert S. Schriebman, 21515 Hawthorne Blvd., Torrance, Calif., for the petitioner. Joyce L. Sugawara, for the respondent.


Memorandum Findings of Fact and Opinion

PARR, Judge:

This case is before the Court on petitioner's motion for summary judgment and respondent's cross-motion for partial summary judgment. The issue for decision is whether the period of limitations expired before respondent mailed a notice of deficiency to petitioner. This issue is dependent upon the legal effect of a Form 872-A (Special Consent to Extend the Time to Assess Tax) executed by the parties. If...

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