Estate of Stella Adler Wilson - Page 6

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          District Counsel, IRS, for 4-1/2 years and then left to enter               
          private practice.  He earned an LL.M. (tax) degree from New York            
          University in 1983.                                                         
               In 1986, Newman was a practitioner working solely on Federal           
          income tax and related matters.  In that year he wrote letters to           
          all of his clients who had pending tax matters, including                   
          decedent, advising them that, due to changes in the law, if they            
          wished to deduct interest on tax liabilities, either "determined"           
          or contested, they had until December 31, 1986, to pay both the             
          tax and the interest thereon in full.  Decedent apparently was              
          motivated by this letter to make her $185,327 payment on December           
          31, 1986, although in a recently filed status report Newman                 
          states that he never heard from decedent in response to his                 
               Petitioner argues that decedent made a voluntary payment of            
          tax on December 31, 1986, in the amount of $89,410, the exact               
          amount of the deficiency for 1980, which, petitioner claims, was            
          "designated to the taxable year 1980".  She urges that the                  
          $89,410 was part of a total remittance of $185,327, the balance             
          of which, it is agreed, the IRS treated as a designated payment             
          of interest.  Petitioner further argues that (1) since decedent's           
          voluntary payment was so designated, respondent was bound to                
          honor her designation; (2) respondent's 1992 reallocations of               

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