John A. Roberts - Page 4

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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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