Court of Appeals for the Third Circuit April 12, 1989, 88-1185 (Harry Holof and Norma Holof v. Commissioner of Internal Revenue)

OPINION OF THE COURT

SCIRICA, Circuit Judge.

In this appeal we must decide whether a defective notice of tax deficiency mailed by the Internal Revenue Service terminates taxpayers’ Form 872-A consent to waive the statute of limitations on assessment of tax deficiencies.