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Pursuant to this Court’s decision, respondent assessed a
$73,053 deficiency in income tax, a $12,313 delinquency addition
to tax under section 6651(a)(1), a $14,611 accuracy-related
penalty under section 6662, and $72,080.39 of accrued interest.
As of January 31, 2006, the outstanding balance due on
petitioner’s 1991 tax liability, including penalties and interest
to that date, was $288,028.05.
During the period October 22, 2000, through mid-January
2004, respondent offset an aggregate amount of $772.64 against
petitioner’s outstanding 1991 tax liability. The offsets were
the following tax refunds claimed by petitioner and his wife on
their jointly filed returns: $56.48 (claimed for 1999), $600.00
(claimed for 2000), $112.96 (claimed for 2001), and $3.20
(claimed for 2002).
On or about July 15, 2004, petitioner was in touch with
Revenue Officer Beth McCullough who had been assigned to collect
petitioner’s outstanding 1991 tax liability. Petitioner provided
Ms. McCullough with a letter along with a seven-page memorandum,
dated July 15, 2004, which set forth background in support of
petitioner’s request that respondent not file an NFTL with
respect to his 1991 tax liability. In the memorandum petitioner
explained that he was 67 years old, had practiced law in Jackson,
Mississippi, for 43 years, and had a good reputation. Petitioner
also outlined the status of his health explaining that he had
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