- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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