Jerome Edward Brown and Mary L. Smith Brown - Page 7




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          abuse his discretion, and we sustain respondent’s determination.5           
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          





























               5  We note that petitioners claim that their account does              
          not reflect the $850 of payments Mr. Brown made to respondent               
          after receiving the notice of determination.  Three letters                 
          petitioners received from respondent, dated near to or shortly              
          after the dates on the last three checks Mr. Brown submitted to             
          respondent, indicate that respondent applied amounts totaling               
          $850 to reduce petitioners’ outstanding 1995 and 1996 tax                   
          liabilities.                                                                




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