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current tax liability should be consequently adjusted by, inter
alia, an abatement of interest pursuant to section 6404(e).
With regard to the second question posed by the Court of
Appeals--if not, whether petitioner timely received notice from
the IRS that his refund had not been applied to his 1987 and 1989
tax deficiencies--we conclude, on the basis of petitioner’s
credible evidence, respondent’s admissions, and the lack of
credibility of the documentary and testimonial evidence
respondent offered--which was contradictory and contained
numerous errors--that petitioner did not receive notice from the
IRS that his refund had not been applied to his 1987 and 1989 tax
deficiencies.
With regard to the third question posed by the Court of
Appeals--if not, whether petitioner’s current tax liability
should be consequently adjusted by, inter alia, an abatement of
interest pursuant to section 6404(e)--we conclude, on the basis
of petitioner’s credible evidence, respondent’s admissions, and
the lack of credibility of the documentary and testimonial
evidence respondent offered--which was contradictory and
contained numerous errors--that petitioner’s current tax
liability should be adjusted by abating the interest for 1989
pursuant to section 6404(e).
Since 1992, petitioner has repeatedly asked respondent for a
payoff figure so that he could pay the liabilities at issue in
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