- 9 - April 3, 2001, entries represent belated recordations of the June 1, 2000, installment agreement. On the basis of the limited evidence in the record and respondent’s failure adequately to explain his own administrative processes or even to maintain a consistent position with respect thereto, we conclude that petitioners and respondent mutually intended to include in the June 1, 2000, installment agreement all years, including 1992, as to which petitioners had unpaid tax liabilities. We further conclude that in drafting the installment agreement, respondent’s employees or agents inadvertently omitted any reference to the 1992 tax year and also inadvertently omitted the corresponding amount of 1992 unpaid tax. We further conclude that, notwithstanding these erroneous omissions, respondent regarded the installment agreement as covering petitioners’ 1992 tax year, as reflected by the April 3, 2001, entry on petitioners’ transcript of account. Consequently, we agree with petitioners that the installment agreement covered their 1992 year. As explained below, however, we disagree with petitioners that the installment agreement, by listing a total “amount owed” for all tax periods that was less than their unpaid 1992 tax liability, thereby abrogated or limited their obligation to pay their 1992 taxes. 6(...continued) Apr. 3, 2001, when the installment agreement was recorded for the other years.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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