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Petitioner's 1988 balance due was assigned to an IRS revenue
officer in Nashville, Tennessee, where petitioner resided at the
time. The revenue officer worked with petitioner to determine
whether petitioner could satisfy his 1988 tax liability. By
letter dated February 26, 1991, petitioner, among other things
not relevant here, stated that he expected to eliminate his 1988
tax liabilities with a loss he expected to report on his 1990 tax
return. On March 27, 1991, the revenue officer closed his
collection file on petitioner's 1988 account, deeming it
uncollectible, after determining petitioner was unable to pay the
amount due. On that same date, petitioner sent the revenue
officer a letter and a copy of petitioner’s 1990 return.
Petitioner filed his 1990 Federal income tax return timely,
which reported a loss of $319,820. However, petitioner did not
file a Form 1045 with his 1990 return with respect to the net
operating loss he sustained.
In March 1992, petitioner contacted the IRS and learned that
he still owed tax, additions to tax, and interest for 1988. By
letter dated May 4, 1992, petitioner requested the revenue
officer to remove the tax, additions to tax, and interest from
his 1988 account as he thought they had been satisfied by his
1990 loss. The revenue officer, by letter dated June 2, 1992,
responded to petitioner’s letter and provided a summary of
petitioner’s 1988 account balance. While the summary reflected
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