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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.
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