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1991 tax liability (1990-1991 amended offer), which totaled
$18,854.93. A document entitled collateral agreement was at-
tached to each of those amended offers-in-compromise. Each such
document stated in pertinent part:
I, Harry K. Kayian Sr, submitted an amended offer dated
12/07/92 in the amount of $23121.40 to compromise an
unpaid Federal Income tax liability, plus statutory
additions, for the period ended December 31, 1987,
December 31, 1988, and December 31, 1989.
We, Harry K. Kayian Sr & Nancy L. Kayian, submitted an
amended offer dated 12/07/92 in the amount of $23121.40
to compromise an unpaid joint Federal Income tax li-
ability, plus statutory additions, for the period ended
December 31, 1990, and December 31, 1991.
The purpose of this letter is to amend those offers by
adding the following provision:
One payment of $23121.40 shall satisfy all offer
payment requirements as to the total sum paid in
full with respect to all offers described herein.
This agreement is contingent upon the acceptance
of the above referenced offers. [Reproduced lit-
erally.]
The 1987 through 1989 amended offer and the 1990-1991 amended
offer gave the following response to a question which requested
the taxpayer to state the reasons why each such offer should be
accepted: "I cannot pay these taxes."
Mr. Lanier sent Mr. Stephens the 1987 through 1989 amended
offer and the 1990-1991 amended offer under a transmittal letter
dated December 8, 1992. That transmittal letter stated in
pertinent part: "The new Offers are for a total of $23,121.40 in
settlement of all income taxes, interest, and penalties for 1987,
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