interamericatech, you are correct in that I should have separated my response. You were correct on one point, the agreement issue, but incorrect on the other, the court extension. Under the FPCA statute, there is specific provision for extension of the SOL under very certain circumstances, as I cited in my response. I had considerable experience in determining SOLs and preparing extensions of them in my years with the Treasury Dept. When this FPCA SOL issue came up long ago,I read the statute thoroughly for my own comfort, and am confident in my statements.
I apologize for not delineating my response regarding which poster I believed was incorrect on which issue. I can appreciate your experience and expertise, having some similar background.
Magic