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It should be noted that * * * [the earlier
extensions] on * * * [the TXMODA transcript] do not
appear on * * * [the MFTRA-X transcript for 1982]. The
latter * * * contains the October 8, 1991, extension of
the statute, and identifies such as a code “550"
transaction; whereas, the alleged extensions on * * *
[the TXMODA transcript] are listed as codes [sic]
“550R” transactions. Whereas * * * [the transaction
codes guide] identifies transaction code “550" as
“Collection Status Extension”, it does not contain a
“550R” transaction code.
We find that the TXMODA transcript entries indicating
petitioner’s execution of the earlier extensions constitute
evidence of their existence, notwithstanding petitioner’s
argument to the contrary. We have repeatedly approved
respondent’s reliance on TXMODA transcripts as verification of
the information and actions reflected therein. See, e.g.,
Tornichio v. Commissioner, T.C. Memo. 2002-291; Schroeder v.
Commissioner, T.C. Memo. 2002-190. Moreover, section 6330(c)(1)
“does not require the Commissioner to rely on a particular
document to satisfy the verification requirement imposed by that
section.” Roberts v. Commissioner, 118 T.C. 365, 371 n.10
(2002). The reference to transaction code “550R” rather than
“550", although unexplained, is of little consequence in light of
the specific reference in each instance to a collection extension
date (“COLL-EXT-DT”) and the entry of a specific date immediately
thereafter; and although there is no explanation for the omission
of any reference to the earlier extensions in the MFTRA-X
transcript for 1982, we draw no negative inference from that
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