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1984, 1985, and 1986, and that respondent should stop collection
from petitioner.
On April 1, 1991, respondent responded to petitioner's
letter that respondent received on January 7, 1991. Respondent
stated that petitioner owed $317.16 for 1984, $13,256.89 for
1985, and $477.94 for 1986 (including penalties and interest to
April 21, 1991). Respondent said that petitioner must pay the
tax due and claim a refund if he did not agree with the
adjustment.
On April 17, 1991, Kelly wrote to respondent's problems
resolution officer in Seattle, Washington, to explain why he
believed respondent's position was incorrect. On April 23, 1991,
respondent assigned petitioner's case to a problems resolution
office. On May 7, 1991, respondent's quality assurance staff
wrote a memo to respondent's problems resolution office. In it,
the quality assurance staff concluded that the assessments were
invalid because respondent assessed more than the amounts shown
on the returns. Also, on May 7, 1991, respondent's problems
resolution office wrote to Kelly and said the assessments were
valid for 1986, but invalid for 1984 and 1985 because respondent
did not issue a notice of deficiency for those years.
On June 24, 1991, respondent abated petitioner's over-
assessment, additions to tax, and accrued interest for 1984,
but did not abate the assessment of tax for amounts shown on
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