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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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