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Ms. Collier’s overpayment for 1998 had reduced the unpaid assess-
ment for 1987 to zero dollars.
Ms. Collier and Mr. Collier jointly filed Form 1040 for 1988
(1988 joint return). Ms. Collier and Mr. Collier did not pay any
tax at the time they filed the 1988 joint return.
On August 28, 1989, respondent assessed $7,049 with respect
to the taxable year 1988 of Ms. Collier and Mr. Collier. Respon-
dent applied $4,171 of tax withheld against that assessment,
which left $2,878 unpaid. Ms. Collier and Mr. Collier did not
enter into an installment agreement or other arrangement to pay
the unpaid assessment for 1988.
In a notice dated April 11, 2000, respondent informed Ms.
Collier that respondent had applied Ms. Collier’s $443 overpay-
ment for 1998 against the unpaid assessment for 1988. Sometime
thereafter, respondent applied a total of $1,165 of Ms. Collier’s
overpayments for certain other taxable years against the unpaid
assessment for 1988.3
3The parties stipulated:
27. Petitioner’s overpayment in the amount of
$865.00 from the 2000 tax year was applied against the
outstanding 1988 tax balance.
28. Petitioner’s overpayment in the amount of
$300.00 from the 2000 tax year was applied against the
outstanding 1988 tax balance.
We believe that the foregoing stipulations are in error in
indicating that both of the overpayments to which they refer
(continued...)
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