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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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Last modified: May 25, 2011