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three prior extensions of the section 6502 period for 1982
(sometimes, the earlier extensions), each of which extended that
limitations period beyond October 8, 1991, the 1991 extension
covering 1982 was, in fact, timely. In making that argument,
respondent points to the TXMODA transcript for 1982, which, he
claims, reflects the existence of the earlier extensions.
The TXMODA transcript lists three dates (May 26, 1988, March
19, 1990, and May 11, 1990) to the right of code number 550R. To
the right of and one line below each of those dates is the
notation “COLL - EXT - DT” (presumably standing for collection
extension date) immediately followed by a later date (December
31, 1993, opposite May 26, 1988; December 31, 1992, opposite
March 19, 1990; and December 31, 1994, opposite May 11, 1990).
The TXMODA transcript also reflects the 1991 extension covering
1982 by means of the same type of entry except that it refers to
code number 550, not 550R. Appeals Officer Mazaroli’s case
memorandum shows that he reviewed a TXMODA transcript during his
consideration of the case.
Petitioner argues that the entries contained in the TXMODA
transcript do not constitute evidence that he agreed to the
earlier extensions, and he concludes: “It was arbitrary and
capricious for the IRS to issue a Notice of Determination with
respect to the June 6, 1983, assessment”. Petitioner supports
his position, on brief, as follows:
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