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Petitioner resided in Washington, D.C., at the time he filed
the petition in this case.
On April 15, 1991, petitioner filed a Federal income tax
(tax) return (return) for his taxable year 1990 (1990 return).
When petitioner filed his 1990 return, he paid the tax due shown
in that return.
At a time not disclosed by the record after petitioner filed
his 1990 return and before September 2, 1996, the Internal
Revenue Service (IRS) conducted an examination with respect to
petitioner’s taxable year 1990. During that examination, the IRS
proposed an increase in petitioner’s tax of $55,609 for that
taxable year, to which petitioner agreed.
On September 2, 1996, respondent assessed the additional tax
of $55,609 to which petitioner had agreed and interest as pro-
vided by law for petitioner’s taxable year 1990.1 (We shall
refer to any unpaid assessed amounts with respect to petitioner’s
taxable year 1990, as well as interest as provided by law accrued
after September 2, 1996, as petitioner’s unpaid 1990 liability.)
1On Feb. 13, 1997, and Jan. 22, 1998, petitioner made pay-
ments with respect to his taxable year 1990 of $3,000 and $6,000,
respectively. In addition, respondent credited a refund of $859
due to petitioner for his taxable year 2001 against the liability
for petitioner’s taxable year 1990.
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