John A. Roberts - Page 11

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               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.              





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