A taxpayer’s consent to give the IRS extra time to assess tax due while it considers the validity of a charitable contribution deduction does not prevent the Service from recalculating the total tax that should have been due in a suit by the taxpayer to claim a refund of taxes paid. The taxpayer entered into an agreement with the IRS to extend the time to assess tax due for 2003 and 2004. The agreement specifically provided that any deficiency assessment that the IRS could impose was to be limited to that resulting to an adjustment of charitable contributions claimed. The case was not resolved administratively and the taxpayer paid the taxes claimed and sued for a refund. He moved for a...