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agreement set forth in the document. Mr. Katzmar then sent
petitioner a letter dated July 9, 2002, verifying approval of the
agreement and enclosing a copy of the executed Form 12257. The
letter stated in part:
The agreement we reached has been approved and we will
complete our processing of your case.
We will adjust your account and figure the interest.
If you haven’t paid the full amount due, the IRS Center
will send a bill for any additional amount you owe. If
you are due a refund, the IRS Center will mail it to
you.
On October 7, 2002, respondent processed the executed Form
12257, abating tax of $1,749.25 and the $1,399 section 6662
penalty. A notice of balance due was issued on that date for
amounts still outstanding. Also on October 7, 2002, Mr. Patel
sent to Ms. Hornstein a letter which opened as follows: “This is
quickly turning into the case that won’t go away. I received a
telephone call from Paula Lane, Appeals Officer, on October 1,
2002. Ms. Lane claims that Christine still owes $2,026.91.”
After recounting various events in petitioner’s dealings with
Ms. Hornstein, the letter continued: “During the times we spoke,
it was clear to both me and the taxpayer that the dollar amounts
we were discussing were the full and total dollar amounts due and
owing by the taxpayer”.
Mr. Patel thereafter, on petitioner’s behalf, prepared a
Form 843, Claim for Refund and Request for Abatement, dated
November 22, 2002. The IRS received and filed this document on
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