John A. Roberts - Page 14

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          for his 1987 and 1988 tax years and to December 31, 2005 for his            
          1982 tax year.”  Petitioner made the same claim (that the 1991              
          extensions were signed by him in blank and later completed by an            
          IRS employee) to Appeals Officer Mazaroli.                                  
               Petitioner’s actions, of which there is evidence, belie his            
          testimony.  He received filled-in, executed copies of the 1991              
          extensions approximately 2 weeks after he signed them; i.e., on             
          approximately October 22, 1991.  The consequence of the                     
          extensions, to extend the period of limitation for collection, is           
          plain on the face of the extensions; yet, apparently, petitioner            
          did not contact the IRS to repudiate the extensions or to                   
          complain about any irregularity in their execution.  Between                
          October 8, 1991, when the extensions were signed by petitioner,             
          and July 3, 2001, when respondent issued the notice of levy                 
          (almost 10 years), petitioner entered into and made numerous                
          payments pursuant to an installment agreement with respondent,              
          which effectively forestalled enforced collection against him (an           
          obvious benefit) until he ceased making payments pursuant to that           
          agreement.  Those actions indicate that petitioner’s claim of               
          invalidity is motivated by a desire to avoid any additional                 
          collection, by levy, of his remaining liabilities to respondent             
          rather than by a bona fide belief in the invalidity of the                  
          extensions.  Under those circumstances, the evidence before                 
          Appeals Officer Mazaroli falls far short of the “clear evidence”            






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