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process petitioner's returns until the time petitioner received
his refunds. She also testified that, if the problem with the
Form W-2 information from the school showing a discrepancy in
wages and FICA wages had been brought to an examiner's attention,
the examiner would not have abated the tax without a tax return's
having been filed. She stated that, even if the mistake had not
been petitioner's fault, the Service would have needed an
original signed tax return, because he was still required to file
a tax return for his 1987 taxable year.
On May 30, 1997, the Service issued to petitioner refund
checks in the amounts of $451.39 and $226.97, respectively, for
his 1987 and 1988 taxable years.3 On June 2, 1997, the Service,
in response to correspondence dated March 24, 1997, abated for
reasonable cause, on the basis of a documented medical condition,
additions to tax for late filing and negligence that had been
assessed for petitioner's 1987 and 1988 taxable years. Pamela
Auer, a revenue agent in respondent's technical unit that
processed Congressional inquiries, including correspondence from
3 The record indicates that the refunds arose as a consequence
of (1) respondent's application of the refunds that petitioners
were due for the taxable years 1992, 1994, and 1995, against the
liability that respondent determined for the taxable year 1987,
and (2) petitioner's earlier payment of $2,022.55 against his tax
liability for 1988.
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