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BILSKI v. C.I.R.

No. 95-60065 Summary Calendar.

69 F.3d 64 (1995)

Stanley C. BILSKI, Jr., and Connie E. Bilski, Petitioners-Appellants; v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

November 20, 1995.

Attorney(s) appearing for the Case

Patrick F. Timmons, Jr., Houston, TX, for petitioners-appellants.

Patricia McDonald Bowman, Washington, DC, Alice L. Ronk, United States Department of Justice, Tax Division, Washington, DC, Stuart L. Brown, Chief Counsel, Internal Revenue Service, Washington, DC, Loretta Argrett, Asst. Atty. General., United States Department of Justice, Washington, DC, Gary Dexter Gray, Department of Justice, Tax Division, Washington, DC, Gary R. Allen, U.S. Department of Justice, Tax Division, Appellate Section, Washington, DC, for CIR.

Before WIENER, PARKER and DENNIS, Circuit Judges:

WIENER, Circuit Judge:

Petitioners-Appellants Stanley and Connie Bilski appeal the judgment of the United States Tax Court (Tax Court), upholding the Internal Revenue Service's (IRS's) deficiency determination. The Bilskis contend that the Tax Court erred by holding that Treasury Form 872-A, Special Consent to Extend the Time To Assess Tax (872-A), is a waiver of the statute of limitations, and thus is not discharged...

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