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Contract analysis / consent-to-extend-statute-form-872.docx
consent-to-extend-statute-form-872.docx
High · 1
Medium · 1
Standard · 0
1. Fixed-Date Consent. This is a fixed-date consent. The expiration date of December 31,
1. Fixed-Date Consent. This is a fixed-date consent. The expiration date of December 31, 2024 is absolute and may not be further extended without the execution of a new and separate consent signed by both parties. This Form 872 is not an open-ended consent, and it is distinct from Form 872-A (Special Consent to Extend the Time to Assess Tax), which provides for an indefinite extension terminable upon notice.
2. Effective Date. This consent is effective on the date it is signed by both parties. It
2. Effective Date. This consent is effective on the date it is signed by both parties. It shall have no force or effect until signed by both the taxpayer (or the taxpayer's authorized representative) and a duly authorized officer or employee of the Internal Revenue Service.
3. Compliance Assurance Process. Penterra Pharmaceuticals Corp. was not a participant in
3. Compliance Assurance Process. Penterra Pharmaceuticals Corp. was not a participant in the IRS Compliance Assurance Process (CAP) for the tax years at issue, including the tax year ended December 31, 2017.
4. No Admission. The execution of this consent by the taxpayer does not constitute an adm
Medium
⚑ Assignment / subcontracting
4. No Admission. The execution of this consent by the taxpayer does not constitute an admission by the taxpayer of any tax liability, nor does it constitute a waiver of any right of the taxpayer except as expressly set forth herein. Similarly, the execution of this consent by the Internal Revenue Service does not constitute a concession by the Internal Revenue Service of any position or issue.
5. Scope of Extension. The extension of the period of limitations effected by this consen
High
⚑ Penalty / liquidated damages
5. Scope of Extension. The extension of the period of limitations effected by this consent applies solely to the assessment of federal income tax (and any related penalties, additions to tax, and interest, to the extent that the assessment of such amounts is dependent upon the period of limitations for assessment of the underlying tax) for the tax year ended December 31, 2017. SIGNATURES Both the taxpayer and the Int
1. Original — Internal Revenue Service (to be transmitted to Lead Revenue Agent Patricia
1. Original — Internal Revenue Service (to be transmitted to Lead Revenue Agent Patricia Dunleavy, Large Business & International Division, Northeast Transfer Pricing Practice, Exam Team ID LB&I-NE-TP-2022-00641, for inclusion in the official examination case file).
2. Copy — Penterra Pharmaceuticals Corp. (to be transmitted to Marcus Whitfield, Vice Pre
2. Copy — Penterra Pharmaceuticals Corp. (to be transmitted to Marcus Whitfield, Vice President, Global Tax, 2200 Independence Boulevard, Princeton Junction, NJ 08550).
3. Copy — Calderwood & Harkness LLP (to be retained in Matter File No. 1018-00009, 1735 M
3. Copy — Calderwood & Harkness LLP (to be retained in Matter File No. 1018-00009, 1735 Market Street, Suite 3100, Philadelphia, PA 19103, Attention: Leonard Cross). End of Form 872 — Consent to Extend the Time to Assess Tax Tax Year Ended December 31, 2017 Penterra Pharmaceuticals Corp. — EIN 22-3741856 Field | Detail IRS Exam Team | LB&I-NE-TP-2022-00641 Division | Large Business & International (LB&I), Northeast T