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Date of increase (or / / / /
decrease)
Amount of increase $
(or decrease)
New installment $
amount
In July 1993, petitioner paid respondent $1,000 to be
applied to his 1985 tax liability. On August 16, 1993,
respondent sent petitioner a letter stating in pertinent part the
following:
We have set up an installment agreement to help you pay
the amount you owe for the tax period(s) shown above.
Your payments are $74.87, due on the 15th of each
month, beginning on Sep. 15, 1993.
* * * * * * *
In about six weeks, we will send you a notice showing
the amount of tax, penalty, and interest you owe. You
do not have to answer that notice.
Petitioner did not receive any other correspondence relating
to his 1985 tax liability until around September 1, 1993, when he
received a payment notice which said that he had a monthly
payment of $74.87 due by September 15, 1993. It said: "Total
balance owed including penalties and interest: $2,695.34."
Respondent sent petitioner a statement each month for 19
months which stated the amount of the payment due ($74.87), the
due date of the next installment, and erroneously stated the
"Total balance owed including penalties and interest", with an
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Last modified: May 25, 2011