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amounts outstanding (plus interest, penalties, and other
additions) for 1982 until December 31, 2005, and for 1986 and
1987 until December 31, 2004 (together, the 1991 extensions).
The TXMODA transcript of petitioner’s account for 1982
reflects the October 8, 1991, extension to December 31, 2005, and
what appear to be three earlier extensions of the period of
limitations on collection of 1982 liabilities:
Date of Extension New Expiration Date
5/26/88 12/31/93
3/29/90 12/31/92
5/11/90 12/31/94
The MFTRA-X transcript for 1982 only reflects the October 8,
1991, extension to December 31, 2005.
On July 13, 1992, petitioner executed an IRS Form 433-D,
Installment Agreement, covering the years in issue (as well as
other taxable years not involved herein) pursuant to which he
agreed to make monthly payments of $200 beginning August 5, 1992,
and for each month thereafter, until his liability for all years
was paid in full. The MFTRA-X transcripts reflect a series of
$200 (and, in a few cases, lesser) payments beginning May 4,
1994, and continuing, generally on a monthly basis for some (but
not all) years, until January 4, 2001, when the last payment was
credited to petitioner’s account. All but six of the payments
were credited to 1982.
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