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Sec. 6651/
Year Form Tax 6656 Penalty Total
1984 940 $ 520.07 $ 182.03 $ 702.10
1984 941 7,184.81 2,491.75 9,676.56
1985 940 904.50 316.58 1,221.08
1985 941 6,681.35 2,322.55 9,003.90
1986 940 911.12 318.89 1,230.01
1986 941 7,301.22 2,536.56 9,837.78
Total $23,503.07 $8,168.36 $31,671.43
On December 12, 1988, petitioner signed two Forms 2504,
Agreement to Assessment and Colection of Additional Tax and
Acceptance of Overassessment–Excise or Employment Tax, agreeing
to the assessment and collection of the above tax liabilities.
The liabilities listed on the Forms 2504 totaled $31,671.43. On
December 16, 1988, petitioner submitted a check to respondent in
the amount of $31,671.43, and respondent applied this payment to
the employment taxes, penalties, and interest due from petitioner
for failure to file employment tax returns, leaving the following
amounts owed by petitioner:
Year Form Tax Penalty Total
1985 940 $ 904.50 $ 316.58 $ 1,221.08
1986 940 911.12 318.89 1,230.01
1986 941 5,066.46 1,879.01 6,945.47
1984-86 W-2 900.00 900.00
Total $6,882.08 $3,414.48 $10,296.56
In 1993, petitioner was contacted by respondent, who claimed
that petitioner had unpaid liabilities flowing from the 1987
examination. After extensive discussions with respondent,
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