James L. Ball - Page 6

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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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