Eldon Harvey Krugman - Page 6




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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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