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On September 3, 1991, Ms. Collier and Mr. Collier jointly
filed Form 1040 for 1989 (1989 joint return), which they signed
on August 29, 1991. In that return, Ms. Collier and Mr. Collier
reported total tax of $10,952 and tax due of $5,554.4 At the
time Ms. Collier and Mr. Collier filed the 1989 joint return, Ms.
Collier did not believe that payment was made of the $5,554 of
tax due shown in that return, and they did not pay any tax at
that time.
On February 3, 1992, respondent assessed $10,952 with
respect to the taxable year 1989 of Ms. Collier and Mr. Collier.
Respondent applied $5,476 of tax withheld against that assess-
ment, which left $5,476 unpaid. Ms. Collier and Mr. Collier did
not enter into an installment agreement or other arrangement to
pay the unpaid assessment for 1989.
Ms. Collier and Mr. Collier jointly filed Form 1040 for 1990
(1990 joint return). Mr. Collier signed that return. Although
Ms. Collier did not sign the 1990 joint return, she intended to
file that return jointly with Mr. Collier and did not file a
separate return for 1990. In the 1990 joint return, Ms. Collier
3(...continued)
pertain to taxable year 2000. The record does not otherwise
disclose the year to which each of those overpayments pertains.
4There was a mathematical error in the computation of the
amount of tax due shown in the 1989 tax return. That return
reported total tax of $10,952 and total payments of $5,476. The
1989 joint return incorrectly reported the amount of tax due as
$5,554. The difference between $10,952 and $5,476 is $5,476.
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