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As of September 27, 1982, respondent transferred $54,372.61
out of Sheldon's and Nancy's 1981 tax liability account and into
their 1980 tax liability account. This was done in connection
with the September 1982 issuance of the $81,054.77 tax refund
check for 1981, described supra, but the transfer was recorded on
respondent's records as of April 15, 1982. After this transfer,
the balance in Sheldon's and Nancy's 1980 tax liability account
was zero.
After Nancy filed the amended tax return for 1980 claiming a
$204,868 refund, respondent abated the 1980 income tax liability,
but only to the extent of $55,923. This abatement then triggered
a refund of tax for 1980 in the amount of $128,715.36. This
refund consisted of (1) a tax decrease in the amount of $55,923,
(2) an abatement of penalty in the amount of $2,052, (3) an
abatement of interest previously assessed in the amount of
$5,940.40, and (4) interest on the overpayment in the amount of
$64,799.96. The refund check for 1980, in the amount of
$128,715.36 was issued on February 5, 1988, and was received by
Nancy.
Bank Accounts, Life Insurance, Etc.
During 1981 Nancy and Sheldon held various bank accounts and
owned stock, as shown in table 7. Sheldon's two individual
checking accounts were in existence at the time Nancy and Sheldon
got married. Nancy did not have signature authority on any of
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