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$89,410--the exact amount of the 1980 income tax deficiency
determined in the deficiency notice. Also, under the same date,
the same transcript reflects as a "Designated Interest Payment"
the amount of $95,916.67. Decedent's total payment, which
appears to have been motivated by Newman's letter to his tax
clients, was in conformity with the provisions of Rev. Proc. 84-
58, supra, which deals extensively with procedures for taxpayers
to make remittances to stop the running of interest on
deficiencies. Rev. Proc. 84-58, supra section 5.03, 1984-2 C.B.
at 503, states that "A taxpayer wishing to stop the running of
all interest must make a payment or deposit sufficient to cover
all accrued interest as of the date of remittance as well as the
entire amount of the underlying tax." This decedent did.
The record is silent as to why the IRS treated the tax
payment as a "subsequent payment" while at the same time treating
the interest payment as a "designated" interest payment.
Whatever may have been intended by the subsequent payment label
in the IRS records, this is merely an entry characterized by the
IRS, and the records to this extent are not dispositive of the
issue. See Estate of Baumgardner v. Commissioner, supra at 459.
Nevertheless, we are satisfied that decedent effectively
designated her total remittance as a payment of 1980 tax and the
interest thereon, notwithstanding the fact that neither party has
located any communication from decedent to the IRS making that
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