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year 1992 (1992 return). When petitioner filed his 1992 return,
he paid the tax due shown in that return.3
At a time not disclosed by the record after petitioner filed
his 1992 return and before September 2, 1996, the IRS conducted
an examination with respect to petitioner’s taxable year 1992.
During that examination, the IRS proposed an increase in peti-
tioner’s tax of $323 for that taxable year, to which petitioner
agreed.
On September 2, 1996, respondent assessed the additional tax
of $323 to which petitioner had agreed and interest as provided
by law for petitioner’s taxable year 1992. (We shall refer to
any unpaid assessed amounts with respect to petitioner’s taxable
year 1992, as well as interest as provided by law accrued after
September 2, 1996, as petitioner’s unpaid 1992 liability.)4
Respondent issued to petitioner the notice and demand for
payment required by section 6303(a) with respect to petitioner’s
unpaid 1992 liability.
On April 15, 1995, petitioner filed a return for his taxable
year 1994 (1994 return). When petitioner filed his 1994 return,
3On Aug. 16, 1993, respondent assessed an addition to tax
under sec. 6651(a)(2) of $3.27 and interest as provided by law.
On Aug. 31, 1993, petitioner paid those assessed amounts.
4We shall refer collectively to petitioner’s unpaid 1990
liability, petitioner’s unpaid 1991 liability, and petitioner’s
unpaid 1992 liability as petitioner’s unpaid liabilities for
1990, 1991, and 1992.
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