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1996, petitioner signed stipulated decisions in which she agreed
that she had deficiencies in income tax of $1,113 for 1988 and
$3,426 for 1989 and was liable for additions to tax of $272.30
for 1988 and $1,086.50 for 1989 for failure to file a return
under section 6651(a) and failure to pay estimated tax under
section 6654. Petitioner also agreed that respondent could
assess and collect the deficiencies, additions to tax, and
interest. Respondent assessed petitioner’s tax for 1988-89 on
March 31, 1997.
C. Petitioner’s Offer In Compromise
Petitioner contacted Fast because petitioner received a
notice (not otherwise described in the record) from respondent
stating that she owed taxes for 1988-89. Fast told petitioner
how to submit an offer in compromise, and that respondent would
not consider her offer in compromise unless petitioner had filed
all required tax returns. Fast checked respondent’s computer
records and discovered that respondent had no record of
petitioner’s having filed returns for 1991-95. Fast told
petitioner that respondent would not collect taxes owed by
petitioner for 1988-89 until March 20, 1998, to give petitioner
time to submit an offer in compromise.
At a time not stated in the record, a friend of petitioner’s
delivered copies of what appeared to be two or three of
petitioner’s returns to Fast. Those copies did not have original
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