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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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Last modified: May 25, 2011