by $18,976). As a result, the 1992 payment, despite satisfying part of the Greers’ 1982 tax liability, was not a "pay ment of the [full] tax,” and therefore did not end the penalty period for the 1982 underpayment. Because this complication is irrelevant to our resolution of the Greers' appeal, we ignore it. 4 . There is a tension between the Greers’ argument and their failure to challenge the IRS's assessment of the amount of the 1995 refund as a tax liability. A similar tension is evident in some of the erroneous nonrebate refund cases. See, e.g., Bilzerian, 86 F.3d at 1069 (stating that although "no erroneous refund— whether rebate or non-rebate — can revive [a paid tax liability],” nonrebate refunds may be recovered through a supplemental assessment); cf. Frontone, 383 F.3d at 662
recognizing and resolving tension among ninth circuit cases applying conflicting versions of the harmless error standard in civil cases recognizing this method recognizing this tension recognizing this rule recognizing this presumption