Eldon Harvey Krugman - Page 9




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               interest computed to October 7, 1996.  Interest will                   
               continue to accrue until the balance due is paid in                    
               full.                                                                  
               On October 10, 1996, petitioner wrote to ask respondent's              
          Appeals Office to consider his case.  On March 4, 1997, an                  
          Appeals officer for respondent wrote to petitioner to acknowledge           
          that respondent's 19 erroneous notices were "misleading", and               
          explained that, despite those notices, petitioner was liable for            
          interest for 1985:                                                          
                    I received your claim for abatement of interest                   
               for 1985 in Appeals.  The installment agreement states                 
               the balance owed as of a certain date.  The installment                
               agreement also states plus all penalties and interest                  
               provided by law.  Thus, interest continues to accrue on                
               the unpaid balance during the installment period until                 
               paid in full.  However, the additional interest which                  
               accrues on the unpaid balance during the installment                   
               period is not recalculated until the end of the                        
               installment period.  I will agree that the statement on                
               your monthly bills "including penalties and interest"                  
               is misleading and I will attempt to get this language                  
               revised.  However, since you did not pay off the stated                
               balance due until March, 1995, I cannot recommend                      
               abatement of interest in excess of what Examination                    
               Division has already recommended.                                      
               On April 10, 1997, one of respondent's Appeals officers                
          issued a final determination of petitioner's claim to abate                 
          interest under section 6404(e).                                             
               On August 17, 1997, respondent issued a levy to petitioner's           
          bank which stated that he had an unpaid assessment for 1985 of              
          $5,426.38 and statutory additions of $147.21, for a total of                
          $5,573.59.  On September 18, 1997, respondent collected $127.96             
          from the levy.                                                              





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