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Plainly, payment of the $20,400 indicates that petitioner’s
advisers understood that he and Wynne had validly consented to an
extension of that period.
Petitioner’s advisers conducted additional discussions with
the IRS in the latter part of 1984, but in July of 1985, the IRS
sent petitioner and his adviser a letter advising petitioner of a
proposed liability of more than $90,000 for his and Wynne’s
taxable year 1980. Again, the advisers made no suggestion that
the collection of the taxes at issue was time-barred. The last
professional adviser hired, in December 1988, was Mr. Boylan, who
ultimately represented petitioner before this Court. Almost 7
years after Mr. Boylan was hired, the question of the validity of
the consent first arose.
In light of all the foregoing, we do not accept petitioner’s
assertion that his signature to the consent was forged.
Petitioner urges strenuously that Wynne possessed enough
animosity toward him to forge documents provided to the IRS. He
points to the startling evidence that Wynne has been convicted of
trying to have him murdered. Evidence of Wynne’s plotting,
however, came to light only in 1989, following a bitter custody
battle. Thus, although the evidence is dramatic, it is not
particularly persuasive as to Wynne’s intentions or state of mind
more than 6 years earlier, when the consent was executed. We
conclude that Wynne’s animosity in 1989 is too attenuated and too
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