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On June 16, 1988, anticipating that respondent would assess
a deficiency for the 1981 tax year, petitioners deposited
$100,000 with respondent in the form of a bond. Petitioners
requested that respondent apply $81,092 to the deficiency and
$18,908 to penalties.
On January 28, 1991, respondent assessed the deficiency for
1981 in the amount of $81,092. Respondent also assessed a
negligence penalty in the amount of $4,055 and interest in the
amount of $116,564.26 pursuant to section 6621(c) (subsequently
repealed by the Omnibus Budget Reconciliation Act of 1989, Pub.
L. 101-239, sec. 7721(b), 103 Stat. 2106, 2399). On April 15,
1991, because the bond was insufficient to offset the deficiency,
interest, and penalty assessed, respondent mailed petitioners a
Reminder of Unpaid Tax for the 1981 tax year. The reminder
stated that petitioners had an outstanding balance of $104,512.36
with regard to the assessment for the 1981 tax year (including
additional interest).2 Petitioners expected to pay the remaining
liability from proceeds of a refund claim for the 1985 tax year.
On April 13, 1992, respondent issued a notice of intent to
levy with regard to the assessment for the 1981 tax year. In
June 1992, Mr. Wish contacted Specialist Todd Brunk of
respondent’s Problem Resolution Office to request a hold on
2 ($81,092 + $4,055 + $116,564.26) - $100,000 + $2,801.10.
The $2,801.10 represented additional interest accrued from the
date of assessment to the date of the notice.
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