Stanley R. Harbaugh and Bonnie L. Harbaugh - Page 5

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          trial, respondent had not located the ACS employee with whom                
          petitioner entered into the agreement.                                      
               Petitioners made 34 payments of $225, commencing September             
          23, 1996, until June 23, 1999.  The first two payments made by              
          petitioners were credited by respondent to petitioners’ 1993                
          income tax deficiency.  The remaining 32 payments were credited             
          to the TFRP.  Petitioners received monthly statements from the              
          IRS reflecting both the installment amount currently due ($225)             
          and petitioners’ total outstanding liabilities.                             
          Remaining Liabilities                                                       
               After petitioners’ 34th payment was credited in June 1999,             
          petitioners’ accounts showed that accrued interest on the TFRP,             
          as well as income taxes and interest thereon, remained due.  The            
          interest on the TFRP was secured by the lien.  On July 22, 1999,            
          after learning from the IRS the amount necessary to release the             
          lien, petitioners made a payment of $1,345.84, and the lien was             
          released.  After the payment on July 22, 1999, petitioners                  
          received another monthly statement dated August 11, 1999, and               
          continued to receive statements through March 15, 2000, showing             
          amounts due with respect to their income taxes.                             
          Requests for Abatement                                                      
               On June 14, 2000, petitioners filed Form 843, Claim for                
          Refund and Request for Abatement, with the IRS, claiming a refund           

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