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certified mail. The letter asks respondent to reduce to $16,350.13
the amount of 1992 overpayment applied to petitioner’s 1993 tax
liability. In or about the 8th week of 1996, respondent posted as
of April 15, 1993, a $221.07 offset to the previously posted
payment of $16,571.20 of 1993 estimated tax.
In or about the 7th week of 1996, respondent posted as of
February 5, 1996, petitioner’s $8,000 payment of 1995 estimated
tax.
In or about the 18th week of 1996, respondent posted as of
April 15, 1996, petitioner’s $2,500 payment of 1995 income tax.
On or about May 2, 1997, respondent sent letters to petitioner
stating that petitioner apparently had not responded to requests
for copies of his tax returns for 1993 and 1994, so respondent
calculated taxes and proposed penalties for those years based on
payor information. On or about May 30, 1997, respondent sent a
similar letter to petitioner about 1995. On or about May 31, 1997,
petitioner responded that his 1993 tax return had been filed on
October 15, 1994, and that that tax return “was ammended [sic] to
lower the overpayment applied from the 1992 return.” See supra
note 4 and related text regarding the $221.07 1992 minimum tax.
On or about June 24, 1997, respondent replied as follows:
Dear Taxpayer:
We are writing you concerning your income tax return(s)
for the year(s) indicated above. [1993]
We have considered the information you sent us on May 31,
1997. Please return a signed copy of your 1993 return with
the completed Schedule A to support your itemized deductions.
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