Kunkel v. Commissioner of Internal Review

Tax Ct. did not err in entering judgment in favor of IRS that required taxpayers to pay $61,514 in additional tax and $12,302,80 in penalties for 2008 tax return, even though taxpayers argued that IRS issued notices of deficiency beyond applicable limitations period. Record showed that IRS had requested and both parties had signed waiver of limitations period for 2008 tax return, but that said waiver contained typographical error that indicated that waiver was for wrong tax return. Tax Ct. could properly reform waiver agreement to cure instant mistake, where only conceivable function of waiver was to extend time to file assessment for relevant 2008 tax return.