-3-
On November 18, 1991, respondent assessed petitioner’s tax
liability for 1990 as shown on petitioner’s tax return. In
addition, respondent assessed an addition to tax of $413 under
section 6651(a) for failure to pay timely the tax due.
On April 19, 1993, respondent assessed additional income tax
due from petitioner of $3,802 due to the inclusion of the
brokerage fee. Petitioner did not dispute that determination by
respondent.
On October 28, 1993, petitioner filed a petition for Chapter
13 bankruptcy relief, which was subsequently converted to a
Chapter 7 case. Petitioner received a discharge on August 15,
1994, but for his 1990 income tax liability.
On August 14, 1995, respondent erroneously abated
petitioner’s income tax liability of $10,325. Respondent also
erroneously abated on the same date the addition to tax and
interest for 1990. (As discussed below, respondent reassessed the
amount of the addition to tax and interest on October 25, 1999.
Starting from January 15, 1996, respondent sent to
petitioner 39 monthly statements which did not reflect any
interest accrued against petitioner. The first monthly statement
showed petitioner’s 1990 income tax deficiency as $3,802.
Respondent concedes that those monthly statements were misleading
because they did not include any accrued interest.
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