- 11 -
by the crediting of 6 payments of $380 each at roughly monthly
intervals from August 21, 1998, through April 11, 1999.7
Respondent argues on brief that petitioners have not "shown
that any payments designated for 1993 * * * were applied to
another year".8 We disagree. We are persuaded on the basis of
the foregoing evidence that petitioners made payments pursuant to
the 1993 installment agreement that respondent credited against
their 1991 and 1992 liabilities. The payments that respondent
has stipulated petitioners made under the 1993 installment
agreement are otherwise unaccounted for in the Forms 4340 in the
record covering petitioners' taxable years 1991 through 2000.
To the extent respondent may be suggesting that the payments
made pursuant to the 1993 installment agreement were
undesignated, or that respondent was otherwise free to apply them
to petitioners' 1991 or 1992 liabilities, we also disagree.
Installment agreements are devices for the collection of the
liability to which they relate. Section 6159(a) authorizes the
7 A portion ($17.24) of the penultimate payment (Mar. 8,
1999) and all ($380) of the last payment (Apr. 11, 1999) were
treated by respondent as overpayments for 1991 and were
transferred to and credited against petitioners' 1992 liability.
8 Respondent also argues that petitioners may not contest
the application of the 1993 installment agreement payments to
1991 because the issue was not raised in their petition or pre-
trial memorandum. However, the notice of determination indicates
that petitioners raised this issue at the Appeals hearing.
Issues raised at the Appeals hearing or otherwise brought to the
attention of the Appeals Office are within our jurisdiction for
review. Magana v. Commissioner, 118 T.C. 488, 493 (2002).
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