Muir v. Commissioner

11 F. App’x 701 (2001)

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Muir v. Commissioner

United States Court of Appeals for the Eighth Circuit
11 F. App’x 701 (2001)

Facts

Ross Muir (plaintiff) was a partner in a limited partnership. Muir timely filed tax returns for the years 1980 and 1981 and included losses attributable to his investment in the partnership. In 1984 and 1985, the Internal Revenue Service (IRS) (defendant) sent Muir Forms 872-A seeking his consent to extend the limitation period to assess deficiencies for the 1980 and 1981 tax years. The language of the forms provided that the consent could be terminated by either Muir or the IRS by executing a Form 872-T notice of termination. The forms lacked language indicating that the consent would expire on a certain date. In 1988, the IRS issued Muir a notice of deficiency denying his claimed losses for the 1980 and 1981 tax years. Muir challenged the assessment in the United States Tax Court, arguing that too much time had passed after filing his returns for the IRS to issue a notice of deficiency for those years. The IRS denied Muir’s petition, and Muir appealed.

Rule of Law

Issue

Holding and Reasoning (Per curiam)

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