Michael Sponberg - Page 7




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            Taxable Year to                                                           
            Which Payment         Date as of Which           Amount of                
           Was Credited         Payment Was Credited     Payment Credited             
                 1986                 03/20/96                $1,000                  
                 1985                 04/20/96                 1,000                  
                 1985                 05/19/96                 1,000                  
                 1985                 06/20/96                 1,000                  
                 1985                 07/20/96                 1,000                  
                 1985                 08/20/96                 1,000                  
                 1985                 09/21/96                 1,000                  
                 1985                 10/22/96                 1,000                  
                 1985                 11/20/96                 1,000                  
                 1985                 12/20/96                 1,000                  
                 1985                 01/19/97                 1,000                  
                 1985                 03/04/97                 1,000                  
                 1984                 03/29/97                 1,000                  
                 1984                 06/01/97                 1,000                  
                 1985                 03/29/98                 1,000                  
               In addition to crediting petitioner’s payments to his                  
          accounts with respect to his taxable years 1984, 1985, 1986,                
          and/or 1990, respondent ultimately:  (1) Credited petitioner’s              
          account with respect to each of his taxable years 1984, 1985, and           
          1987 with certain credits and (2) debited petitioner’s account              
          with respect to each of his taxable years (a) 1984 and 1985 to              
          reflect certain refunds to him, (b) 1984, 1985, and 1986 to                 
          reflect the transfer of certain credits from each of those                  
          taxable years to his taxable years 1984, 1985, and/or 1987, and             
          (c) 1984, 1985, and 1987 to reflect certain corrections of                  
          payments and/or certain reversals of credits.  As reflected in              
          Form 4340 with respect to each of petitioner’s taxable years 1984           
          and 1985 and in respondent’s statement of petitioner’s account              






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