John P. and Sharon Lynn - Page 3

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               I/We agree that the federal taxes shown above, plus all                
               penalties and interest provided by law, will be paid as                
               follows:  $100.00 will be paid on October 24, 1996 and                 
               $100.00 will be paid no later than the 24th of each                    
               month thereafter until the total liability is paid in                  
               full.                                                                  
          Additionally, petitioners agreed to the following conditions:               
               While this agreement is in effect, [petitioners] must                  
               file all federal tax returns and pay any taxes [that                   
               petitioners] owe on time.                                              
                         *    *    *    *    *    *    *                              
               If [petitioners] don’t meet the conditions of this                     
               agreement, [respondent] will cancel it, and may collect                
               the entire amount [that petitioners] owe by levy on                    
               [petitioners’] income, bank accounts, or other assets,                 
               or by seizing [petitioners’] property.                                 
                         *    *    *    *    *    *    *                              
               [Respondent] will apply all payments on this agreement                 
               in the best interest of the United States.                             
               Pursuant to the installment agreement, petitioners submitted           
          monthly $100 payments to respondent.  From October of 1996                  
          through December of 1997, respondent applied the payments to                
          petitioners’ 1990 and 1994 liabilities as follows:                          
               Date recorded     Amount of payment       Tax year                     
               10/23/96       $100                          1990                      
               11/25/96            100                      1994                      
               12/18/96            100                      1994                      
               1/17/97             100                      1990                      
               2/20/97             57                       1994                      
               3/30/97             100                      1994                      
               4/24/97             100                      1994                      
               5/29/97             100                      1994                      
                                                                                     







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