-4-
On January 26, 1996, petitioner made a first payment of $29
toward his 1990 income tax liability.
In March 1996, petitioner entered into an installment
agreement to pay his 1990 income tax liability.3 The terms of
this agreement required that petitioner make 39 payments of $72
toward his 1990 tax liability. From March 29, 1996, to June 25,
1999, petitioner made 39 payments of $72. In total, petitioner
paid $3,823 toward his 1990 income tax liability.
On July 14, 1999, respondent sent to petitioner a monthly
statement showing that the current balance on his 1990 income tax
liability was $845. A note to that statement provided: “Penalty
and interest totals are cumulative, but are not calculated to the
Due Date shown above. If a payoff total is required, please call
the telephone number shown below.” Petitioner called the
telephone number shown on that statement. Later, petitioner
contacted Insolvency Technician Molly Modin. Based on those
conversations, on July 20, 1999, petitioner sent to the Internal
Revenue Service a check for $845 which he believed to be the
remaining outstanding balance of his 1990 tax liability. On July
23, 1999, this amount was applied to petitioner’s 1990 income tax
liability.
3 The record does not contain a copy of the installment
agreement, nor does it disclose all of its relevant terms.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011