- 6 - 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 anPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011