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The parties’ disagreement whether the period of limitations
governing collection for the taxable years 1982 and 1985 remained
open in May 1998 turns on the specific date in 1990 that
petitioner and her husband submitted the offer-in-compromise in
question. Relying on entries appearing in transcripts of
petitioner’s accounts, specifically Forms 4340, Certificate of
Assessments, Payments, and Other Specified Matters, for the
taxable years 1982 and 1985, and a Master File Transcript
(TAXMODA) for the taxable year 1985, respondent determined that
the offer-in-compromise was submitted on January 4, 1990, making
the 1998 levy timely. Relying primarily on correspondence from
the revenue officer tasked with reviewing petitioner’s offer-in-
compromise, petitioner asserted that the offer was submitted on
November 29, 1990, in which case the 1998 levy was untimely.
There is no dispute that petitioner withdrew the offer-in-
compromise on June 28, 1991.
In November 2000, petitioner requested the assistance of the
Internal Revenue Service Taxpayer Advocate Service (TAS) with
regard to her refund claims for the taxable years 1982 and 1985.
By letter dated September 11, 2001, TAS informed petitioner that
its review of the matter revealed that, as of May 1998--the date
respondent collected funds from petitioner’s retirement account--
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