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$995 was applied to his account for 1988. On March 18, 1996, a
credit (from petitioner's 1995 taxable year) of $809 was
similarly applied to 1988. When the March 18, 1996, payment was
applied, petitioner's entire liability for tax and penalties for
1988 was extinguished. The sum of $252.63, the balance after
satisfying the tax and penalty liability, was applied to interest
that had accrued for 1988. In March 1996, petitioner submitted
an Offer in Compromise with respect to the balances owed for
1988, 1990, and 1991. On May 9, 1996, after additional exchanges
of correspondence between petitioner and respondent, petitioner's
Offer in Compromise was rejected on the ground that there was no
doubt as to liability. Also on or about May 9, 1996, petitioner
telephoned respondent's Glendale, California, office to ascertain
the balance then outstanding on his accounts for 1988, 1990, and
1991. An employee of respondent told petitioner that the
following amounts had been assessed and remained outstanding:
1988--nothing; 1990--$2,196; and for 1991--$2,492. Respondent’s
employee also told petitioner to add $100 to each of these
amounts. Petitioner understood these amounts to be the full
amounts of his liabilities for these years, including all tax
due, penalties and interest. On May 30, 1996, petitioner paid
respondent the amounts of $2,296 for 1990 and $2,592 for 1991.
These payments were credited to petitioner’s 1990 and 1991
accounts on May 30, 1996. On June 24, 1996, respondent assessed
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