- 15 -
that we had previously decided, specifically including Adler v.
Commissioner, T.C. Memo. 1995-148, revd. 86 F.3d 378 (4th Cir.
1996).
J. Appeal, Assessment, and Collection
Following a Rule 155 computation, the Decision in the
present case was entered on January 31, 1996. On February 20,
1996, petitioners filed a notice of appeal. Petitioners did not,
however, file a bond to stay assessment and collection. See sec.
7485(a). Accordingly, on May 21, 1996, respondent assessed the
deficiencies in income and excise taxes as redetermined in our
Decision.10
Subsequently, petitioners made two substantial payments in
partial satisfaction of the foregoing assessment. Thereafter, in
response to a "final notice" dated July 29, 1996, petitioners
entered into an installment payment agreement with respondent on
August 20, 1996. See sec. 6159. Petitioners ultimately made the
following payments on the indicated dates:
Date Amount
6/5/96 $25,000
7/16/96 25,000
9/10/96 243
10/7/96 286
11/7/96 286
10 Respondent also assessed interest. See sec. 6601(a),
(e)(1).
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