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from joint and several liability) with respect to the 1990 tax
deficiency. Around October 1993, respondent informed Ms. Bacon
that respondent had decided to grant that relief to her. None-
theless, on March 7, 1994, respondent assessed the 1990 tax
deficiency (assessed 1990 tax deficiency) against petitioner and
Ms. Bacon.
For reasons not disclosed by the record, respondent inadver-
tently and erroneously failed to adjust the joint account that
respondent maintained for petitioner and Ms. Bacon (joint ac-
count) in order to reflect the determination that respondent made
around October 1993 to grant Ms. Bacon relief from joint and
several liability. Respondent ultimately became aware of respon-
dent’s failure to adjust the joint account in order to reflect
that determination. On May 29, 1998, a so-called 2-Way Memo was
prepared in which respondent’s personnel responsible for making
changes to the joint account were instructed to transfer the
assessed 1990 tax deficiency and interest thereon from the joint
account to a nonmaster file (NMF) account to be established only
in petitioner’s name (petitioner’s NMF account). On June 18,
1998, the assessed 1990 tax deficiency and interest thereon
reflected in the joint account were transferred to petitioner’s
NMF account. At no time throughout the period during which
respondent was considering and taking action with respect to Ms.
Bacon’s request for relief from joint and several liability was
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