- 11 - Although largely duplicative of other stipulated documents, viz, the certificate of assessments and payments and the MFTRA-X transcript for 1982, the TXMODA transcript similarly reflects petitioner’s post-1991 payments in discharge of a portion of his outstanding liabilities for 1982. Therefore, it is relevant to respondent’s contention (discussed in Section IV) that petitioner failed to repudiate the 1991 extensions after he signed them3 and that, in fact, he sought to benefit from them by avoiding immediate, enforced collection of those liabilities. In addition, the TXMODA transcript indicates that petitioner extended the section 6502 period with respect to his 1982 assessed liabilities beyond October 8, 1991, on three separate occasions beginning in 1988. Therefore, it is also relevant to and supportive of respondent’s argument that the section 6502 period with respect to the 1983 assessment had not expired when petitioner signed the 1991 extension covering 1982 on October 8, 1991. The transaction codes guide identifies the numerical codes keyed to the entries on the TXMODA transcript. Therefore, it is an aid to understanding that transcript. 3 The payments reflected in the transcripts (and, in particular, payments made after expiration of the statutory period of limitations on collection provided for in sec. 6502(a)(1) applicable to the years in issue) are evidence of petitioner’s continuing belief that the assessed liabilities remained subject to collection because of the 1991 extensions.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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