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LYON v. COMMISSIONER

Docket No. 3584-92.

68 T.C.M. 224 (1994)

T.C. Memo. 1994-351

Michael Lyon v. Commissioner.

United States Tax Court.

Filed July 26, 1994.

Attorney(s) appearing for the Case

David H. Singer, 225 Broadway, New York, N.Y., for the petitioner. Peter J. Graziano, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1985 in the amount of $28,079. Petitioner having conceded the disallowance of a foreign earned income exclusion under section 911,1 the sole issue for consideration is whether a valid Consent To Extend the Time To Assess Tax (Form 872) was executed for the...

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