- 12 -
For the foregoing reasons, we find that both Exhibits 18-J
and 19-J are relevant to the issues raised herein. Therefore, we
overrule petitioner’s objections to our receiving into evidence
those exhibits.
IV. Validity of the Extensions
A. Alleged Procedural Irregularities
The parties have stipulated the admission into evidence of
the 1991 extensions, which, together, purport to extend the
limitations period on collection, for 1982, until December 31,
2005, and, for 1987 and 1988, until December 31, 2004. Both
extensions were signed by petitioner on October 8, 1991, and by
Revenue Officer Michael J. Quinn, on October 15, 1991. Appeals
Officer Mazaroli concluded that, in accordance with customary IRS
practice, the 1991 extensions were completed by the revenue
officer, submitted to petitioner for his signature, and, after
review by the revenue officer and “a manager”, signed and dated
by the revenue officer. Petitioner disputes that finding and
states that he was required to, and did, sign the 1991 extensions
in blank (without knowledge of the extension dates) as a
condition precedent to the IRS agreeing to enter into an
installment payment agreement with petitioner. Petitioner’s
stipulated testimony is that he received filled-in, executed
copies of the 1991 extensions approximately 2 weeks after he
signed them; i.e., on approximately October 22, 1991.
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