Raymond B. Magana - Page 3




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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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