- 3 - Respondent assessed taxes, interest, and penalties for the years in issue as follows: Date of Year Assessment Tax Interest Penalties 1982 6/6/83 $11,468 $235 $834 1982 8/12/85 2,321 -- 1,161 1982 9/17/01 -- 55 -- 1987 11/28/88 6,835 147 36 1988 7/17/89 9,209 117 53 Literal transcripts (MFTRA-X1) of petitioner’s accounts for the years in issue show that, after application of petitioner’s payments for those years, the outstanding balances due (including interest and penalties not yet assessed), as of December 31, 2001, were as follows: Accrued Accrued Year Tax Interest Penalties 1982 -- $60,391 -- 1987 $1,682 4,232 $442 1988 3,548 6,940 793 On October 8, 1991, petitioner signed two Internal Revenue Service (IRS) Forms 900, Tax Collection Waivers, which, on their face, extend the period of limitations on collection of assessed 1 “A literal transcript is a transcript in ‘plain English’ with a minimum of ‘computerese’.” Keene v. Commissioner, T.C. Memo. 2002-277 n.7. Each of the transcripts in evidence is derived from current account information in respondent’s master file. In general, transcripts are obtained by entering various command codes (such as MFTRA or TXMODA) into respondent’s integrated data retrieval system (IDRS) in order to obtain a particular transcript. (IDRS is essentially the interface between respondent’s employees and respondent’s various computer systems.) See Crow v. Commissioner, T.C. Memo. 2002-149 n.6.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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