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necessary to negate the presumption of official regularity upon
which he relied.
Petitioner’s actions after he signed the 1991 extensions
also amount to a ratification of the extensions, even assuming
they were blank when he signed them and, therefore, improperly
obtained. See United States v. Vassallo, Inc., 274 F.2d 791, 794
(3d Cir. 1960); Crown Willamette Paper Co. v. McLaughlin, 81 F.2d
365, 368 (9th Cir. 1936). Moreover, respondent’s willingness to
forgo enforced collection, enter into an installment agreement,
and accept small monthly payments over a 10-year period
demonstrates respondent’s reliance on the validity of the
extensions. “A waiver proper on its face, relied on by the
Commissioner, cannot be later repudiated by the taxpayer.” Cary
v. Commissioner, 48 T.C. 754, 763 (1967).
We sustain Appeals Officer Mazaroli’s finding that the 1991
extensions were valid and were not improperly obtained.
B. Whether the 1991 Extension Covering 1982 Is
Effective To Permit Collection of Accrued Interest
Relating to the 1983 Assessment
Petitioner alleges that the 1991 extension covering 1982,
even if validly obtained, was not effective to extend the section
6502 period for collection of interest4 attributable to the 1983
4 Because petitioner’s account for 1982 shows a zero
balance of tax owed, petitioner’s argument necessarily concerns
the accrued interest attributable to the 1983 assessment. See
sec. 6601(g), allowing interest on any tax to be assessed and
(continued...)
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