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made an additional tax assessment of $6,500 (bringing the total
assessment to the $14,152 petitioners reported as due on the
amended return) and allowed an additional withholding credit to
conform those credits to the amount petitioners reported.
Petitioners did not pay the entire tax reported as due on the
amended return, and there was an outstanding liability for 1993
after respondent made the assessments just described.4
In 1998, petitioners entered into an installment agreement
with respondent to satisfy their 1993 tax liability (1993
installment agreement). Petitioners made periodic payments
totaling $2,617 pursuant to the 1993 installment agreement from
July 1998 to April 1999. However, respondent applied $2,219.76
of these payments to the 1991 quick assessment and the $397.24
balance to a 1992 assessment.
Petitioners received an extension to June 15, 1995, for
filing their return for 1994 and on June 20, 1995, filed a joint
Federal income tax return for 1994 reporting a tax due of $4,114.
After withholding credits of $3,923, petitioners had a balance
due of $191. They submitted a payment of $195.84 on August 21,
1995, which satisfied all outstanding assessments for 1994.
4 Respondent also abated the addition to tax for failure to
pay estimated tax and partially abated the late filing addition
to tax and interest to bring the assessments into conformity with
the amounts petitioners reported on the amended return.
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