Philip L. and Sara N. Eckert - Page 9

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          reversals when the two checks were returned for insufficient                
          funds.5                                                                     
               After applying the $10,200 payment to petitioners’ 1994                
          taxable year, which respondent has agreed to do, a portion of               
          petitioners’ 1994 tax liability remains outstanding.                        
          Accordingly, respondent’s determination to proceed with                     
          collection of petitioners’ outstanding 1994 Federal income tax              
          liability is sustained.                                                     
               To reflect the foregoing,                                              


                                                  Decision will be                    
                                             entered for respondent.                  


















               5 The transcript of petitioners’ 1994 taxable year does not            
          reflect the $10,200 payment by petitioners in July 2001 that was            
          applied to petitioners’ 2000 taxable year.                                  





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