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that quarter. Following a similar pattern, petitioner continued
to accrue employment tax liabilities for subsequent quarters,
including the first and fourth quarters of 1994 and the first
three quarters of 1996.
In June of 1994, petitioner and respondent entered into an
agreement whereby, following a payment of $400 on June 15,
petitioner agreed to make weekly payments of $250 until
petitioner’s then-outstanding employment tax liabilities were
paid in full. Payments of $400 and $600 were applied to
petitioner’s employment tax liability for the fourth quarter of
1993 on November 8, 1996, and December 19, 1996, respectively.
In response to an inquiry made in a telephone conversation
that occurred during January of 1997, an employee of respondent
advised Mr. Halse that petitioner’s then-outstanding employment
tax liabilities were as follows: Fourth quarter of 1993–-
$6,088.36; first quarter of 1994--$3,679.45; fourth quarter of
1994--$435.69; first, second, and third quarters of 1996--
$1,277.57. On January 15, 1997, Mr. Halse delivered to
respondent’s Sarasota office four certified checks in amounts
corresponding to the account balances provided to Mr. Halse by
respondent’s employee. On January 16, 1997, the checks were
applied to the designated account balances for the above-
referenced quarters.
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