Court of Appeals for the Eighth Circuit June 10, 2004, 03-2662 (Larry Armstrong Coleen Armstrong v. United States)

HEANEY, Circuit Judge.

In 1995, the Internal Revenue Service (IRS) issued Larry D. and Coleen Armstrong a Notice of Deficiency for underpayment of taxes in 1989 and 1991. In 1999, the Armstrongs satisfied this debt with a payment of $156,142, the amount that remained due at that time.