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).
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