112 T.C. No. 16 UNITED STATES TAX COURT ELDON HARVEY KRUGMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20474-97. Filed April 28, 1999. P filed his 1985 Federal income tax return on Oct. 27, 1992. In July 1993, P signed an installment agreement for 1985. From August 1993 to March 1995, R sent 19 monthly payment notices for 1985 to P which erroneously said they included interest. The notices also said that P was reducing his unpaid balance for 1985 to zero by making the monthly payments. P timely paid the installments. On Aug. 9, 1995, R sent a notice to P which said that he owed $6,019.10 for 1985. This notice was inconsistent with the 19 installment payment notices R had sent to P. P believed the Aug. 9, 1995, notice was in error, and he asked R to abate the amount. R concedes that P is not liable for interest that accrued from Apr. 12, 1993 (the day R sent the first notice which erroneously omitted interest), to Aug. 9, 1995 (the day R told P he owed $6,019.10 for 1985).Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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