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accrued on petitioner’s 1988 income tax liability after the due
date of his 1990 return, April 15, 1991, because of respondent’s
retroactive application of the 1990 carryback on that date.
However, petitioner contends that respondent should abate the
interest that accrued on petitioner’s outstanding self-employment
taxes and additions to tax from April 15, 1991, to the present.
Petitioner claims the revenue officer in respondent's Nashville
office agreed to apply petitioner’s 1990 carryback to eliminate
completely petitioner’s 1988 income and self-employment tax
liabilities, as well as all the additions to tax and interest
associated with petitioner’s 1988 tax year. Petitioner claims
the revenue officer in respondent’s Nashville office told him not
to file a Form 1045 with his 1990 return. While petitioner
conceded at trial that the 1990 carryback could not be used to
eliminate his liability for self-employment taxes, additions to
tax, or interest, petitioner claims he was unaware of this fact
until early 1996. Petitioner claims that, if the revenue agent
had not advised him not to file a Form 1045, or if respondent had
properly applied the 1990 carryback in 1991, then petitioner
would have become aware at that time that the 1990 carryback
could only be used to eliminate income tax liability. Petitioner
claims he could have paid the remaining 1988 liabilities in
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