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petitioners’ attorney sent respondent six checks.2 Accompanying
the checks was a letter, dated February 12, 1999, which stated,
in part:
If it has not already occurred, we request that
the Service apply the cash bonds previously posted on
behalf of Mr. and Mrs. Hillenbrand for 1993, 1994, and
1995 to the tax deficiencies for those years, and we
request that the enclosed checks be applied as
additional payments with respect to those deficiencies.
The February 12, 1999, letter further indicated the
following allocations of the funds represented by the checks
enclosed with the February 12, 1999, letter: As to petitioner W.
August Hillenbrand, $187,957 should be applied to 1993, $26,531
should be applied to 1994, and $71,035 should be applied to 1995;
as to petitioner Nancy K. Hillenbrand, $180,949 should be applied
to 1993, $24,466 should be applied to 1994, and $70,718 should be
applied to 1995.
The foregoing specific allocations were further reflected on
the lower left-hand side on the face of each of the six checks
enclosed with the February 12, 1999, letter. Each check
identified the specific individual and tax year. Check No. 4405,
for $187,957, is marked “1993 W August Hillenbrand”. Check No.
4406, for $26,531, is marked “1994 W August Hillenbrand”. Check
No. 4407, for $71,035, is marked “1995 W August Hillenbrand”.
2These six checks were different from the six checks
remitted to respondent by petitioners and their children on Sept.
15, 1998.
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