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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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