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whether his 1989 liability had been fully paid as of August 28,
2006, and, if not, the amount of his outstanding balance for 1989
as of that date.
In his August 28, 2006, status report, respondent stated:
(1) That petitioner’s balance due for 1989 as of August 28, 2006,
was $1,659.38; (2) that petitioner had paid his tax and additions
to tax for 1989 in full and that the balance due was interest;
(3) on March 27, 2003, petitioner paid $11,925 towards his 1989
tax year on the basis of an IRS employee’s misstatement that this
amount would pay his balance in full; (4) the payment, however,
resulted in a credit balance of $24.03 being reflected on
petitioner’s 1989 account; (5) petitioner’s 1989 account balance,
however, mistakenly did not include $442.63 of interest due (in
addition to the $11,925) as of March 27, 2003; (6) respondent
admitted that pursuant to section 301.6404-2(c), Example (11),
Proced. & Admin. Regs., quoting petitioner an incorrect balance
due was a ministerial error; (7) on September 14, 2005,
respondent issued petitioner an erroneous refund of $1,240.78 for
1989; and (8) on September 14, 2005, petitioner’s 1989 account
reflected a balance due of $90.
Discussion
The extended proceedings of this case recounted supra have
brought to light the numerous misstatements and errors made by
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