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interest computed to October 7, 1996. Interest will
continue to accrue until the balance due is paid in
full.
On October 10, 1996, petitioner wrote to ask respondent's
Appeals Office to consider his case. On March 4, 1997, an
Appeals officer for respondent wrote to petitioner to acknowledge
that respondent's 19 erroneous notices were "misleading", and
explained that, despite those notices, petitioner was liable for
interest for 1985:
I received your claim for abatement of interest
for 1985 in Appeals. The installment agreement states
the balance owed as of a certain date. The installment
agreement also states plus all penalties and interest
provided by law. Thus, interest continues to accrue on
the unpaid balance during the installment period until
paid in full. However, the additional interest which
accrues on the unpaid balance during the installment
period is not recalculated until the end of the
installment period. I will agree that the statement on
your monthly bills "including penalties and interest"
is misleading and I will attempt to get this language
revised. However, since you did not pay off the stated
balance due until March, 1995, I cannot recommend
abatement of interest in excess of what Examination
Division has already recommended.
On April 10, 1997, one of respondent's Appeals officers
issued a final determination of petitioner's claim to abate
interest under section 6404(e).
On August 17, 1997, respondent issued a levy to petitioner's
bank which stated that he had an unpaid assessment for 1985 of
$5,426.38 and statutory additions of $147.21, for a total of
$5,573.59. On September 18, 1997, respondent collected $127.96
from the levy.
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