John A. Roberts - Page 3

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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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