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Background
At the time the petition was filed, petitioner resided in
Bartlesville, Oklahoma.
Based on an amended Federal income tax return filed by
petitioner for 1980, on April 23, 1984, respondent assessed
against petitioner the above $472,532 Federal income tax
deficiency.
In November of 1988, petitioner submitted an offer in
compromise that was rejected by respondent. In October of 1990,
the statute of limitations on collection under section 6502 was
amended to provide a 10-year period from the date of assessment
for the collection of Federal taxes (extended from 6 years).
Omnibus Budget Reconciliation Act of 1990, Pub. L. 101-508, sec.
11317(a)(1), 104 Stat. 1388-458.
On May 19, 1995, the United States brought an action in the
District Court for the Northern District of Oklahoma to reduce to
judgment respondent’s above $472,532 unpaid Federal income tax
assessment against petitioner for 1980. United States v. Magana,
No. 95-CV-462-K (N.D. Okla., Jan. 26, 2000). In the above
District Court proceeding, petitioner asserted that the period of
limitations on collection of petitioner’s unpaid tax liability
for 1980 had expired as of May 19, 1995, the day on which the
above suit was filed by the United States against petitioner.
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Last modified: May 25, 2011