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$590 per month.2 Petitioners made 27 equal monthly payments in
the amount of $590 each. The payments commenced in approximately
August 1994.3
In October 1996 petitioners requested from the IRS a written
statement as to the balance of taxes due. By letter dated
October 3, 1996, respondent provided petitioners a statement as
to the balance of taxes due. The attachments reflected the
following information as to petitioners’ tax liabilities:
Form Tax Year Balance Due As of (date)
1040 1983 $1,692.15 11-03-96
1040 1984 2,398.44 11-03-96
1040 1988 139.98 11-03-96
1040 1990 2,958.92 11-03-96
1040 1991 3,535.22 11-03-96
1040 1993 1,929.13 11-03-96
Petitioners made a payment of $11,580, dated December 30,
1996, which was applied by the IRS on January 7, 1997. The IRS
acknowledged the payment by letter dated February 4, 1997.
Petitioners were advised that their accounts for the tax years
1984, 1988, and 1990 were paid in full. By letter dated February
2 The installment agreement was not made part of the
record.
3 Petitioners assert that 28 payments were made. Since
there are other issues in this proceeding relating to the
application of payments and whether respondent is bound by a
response to a balance inquiry, we do not deem the dispute about
whether petitioners made 27 payments or 28 payments to be
relevant to our findings and conclusions.
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Last modified: May 25, 2011