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CORRADO v. COMMISSIONER

Docket Nos. 607-89, 608-89, 609-89, 610-89.

61 T.C.M. 2944 (1991)

T.C. Memo. 1991-278

Joseph J. and Bonnie L. Corrado, et al. v. Commissioner.

United States Tax Court.

Filed June 20, 1991.

Attorney(s) appearing for the Case

Thomas B. Rutter, The Curtis Center, Independence Square West, Philadelphia, Pa., for the petitioners. Russell K. Stewart, for the respondent.

Memorandum Findings of Fact and Opinion

COLVIN, Judge:

These cases1 are before the Court on petitioners' motion for summary judgment. The issue for decision is whether the notices of deficiency were timely issued. To be timely, they must have been issued within 90 days after petitioners revoked their consent to extend the time for assessment and collection of tax (Form 872-A). Revocation of a Form 872-A is done by use of a Form...

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