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communications with Appeals Officer Baker, that it covered all
years for which they owed tax, including 1992.
The installment agreement lists the “Amount owed” as $1,455
and states that petitioners agree to pay this amount, plus
interest and penalties, in monthly installments of $125,
commencing April 15, 2000, and continuing until the total
liability is paid in full.2 Pursuant to this agreement,
petitioners made the following payments, as reflected in
respondent’s transcripts of account:
July 14, 2000 $125
Aug. 23, 2000 130
Sept. 18, 2000 125
Nov. 6, 2000 125
Nov. 16, 2000 125
Respondent’s transcripts of account reflect that the first
three payments were credited against petitioners’ 1991 tax
liability, as was $9.42 of the November 6, 2000, payment, which
apparently brought petitioners’ 1991 balance to zero. The
$115.58 balance of the November 6, 2000, payment and the one
2 The record does not reveal why the Form 433-D states that
the first installment payment was due 2-1/2 months before
petitioners signed the Form 433-D, Installment Agreement (the
installment agreement). We surmise that there was a delay
between the preparation of the Form 433-D and petitioners’
signing it.
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