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classifying the 1988 liability as uncollectible or in failing to
take more vigorous collection sooner is immaterial. This
conclusion is bolstered by the legislative history of section
6404, which states: “if a taxpayer files a return but does not
pay the taxes due, this provision would not permit abatement of
this interest regardless of how long the IRS took to contact the
taxpayer and request payment.” H. Rept. 99-426, supra at 844,
1986-3 C.B. (Vol. 2) at 844; S. Rept. 99-313, supra at 208, 1986-
3 C.B. (Vol. 3) at 208.
This is not a case where, after reporting a tax liability on
the return and failing to pay it, the taxpayer was misled by
incorrect information from respondent to make payment of less
than the full balance due. Cf. Douponce v. Commissioner, T.C.
Memo. 1999-398. Respondent did nothing that would have misled
petitioner into believing that the 1988 liability was less than
she and Frank reported on their 1988 joint return or that the
liability had been previously satisfied. As far as the evidence
shows, respondent never notified petitioner that the 1988
liability had been classified as uncollectible. In 1990,
respondent notified petitioner that her claimed 1989 refund was
being applied to the 1988 liability. In 1994, petitioner
received a similar notification shortly after claiming a refund
on her 1993 tax return. As far as the record reveals, in neither
instance did petitioner inquire of respondent why her claimed
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