Sandrus L. Collier - Page 8




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          and Mr. Collier reported total tax of $10,539 and tax due of                
          $5,521.  Ms. Collier and Mr. Collier did not pay any tax at the             
          time they filed the 1990 joint return.                                      
               On May 20, 1991, respondent assessed $10,539 with respect to           
          the taxable year 1990 of Ms. Collier and Mr. Collier.  Respondent           
          applied $5,018 of tax withheld against that assessment, which               
          left $5,521 unpaid.  In November 1997, Mr. Collier entered into             
          an installment agreement (1997 installment agreement) with                  
          respect to the unpaid assessment for 1990.5                                 
               Ms. Collier and Mr. Collier jointly filed Form 1040 for 1991           
          (1991 joint return).  Mr. Collier signed that return.  A signa-             
          ture for “Sandrus Collier” appeared under the signature of Mr.              
          Collier in the 1991 joint return.  Ms. Collier intended to file             
          that return jointly with Mr. Collier and did not file a separate            
          return for 1991.  In the 1991 joint return, Ms. Collier and Mr.             
          Collier reported total tax of $12,778 and tax due of $8,528.6  At           
          the time Ms. Collier and Mr. Collier filed the 1991 joint return,           
          Ms. Collier did not believe that payment was made of the $8,528             
          of tax due shown in that return, and they did not pay any tax at            


               5The record does not disclose whether Mr. Collier made any             
          payments under the 1997 installment agreement.                              
               6There was a mathematical error in the computation of the              
          amount of tax due shown in the 1991 joint return.  That return              
          reported total tax of $12,778 and total payments of $4,628.  The            
          1991 joint return incorrectly reported the amount of tax due as             
          $8,528.  The difference between $12,778 and $4,628 is $8,150.               





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