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2. Application of Installment Payments
Petitioner alleges that for some months he made monthly
installment payments of $750 each; he has been vague and
inconsistent in describing the total amount of installment
payments he claims to have made.10 Nevertheless, petitioner
argues on brief that if his installment payments to the IRS had
been correctly credited to his account, he would have no
outstanding balance due for any year relevant to these cases. He
contends that respondent erred in failing to follow “standard
accounting practices” so as to apply his payments “to the oldest
principal balance first”.
Petitioner has failed to establish that respondent committed
error in this regard. The record indicates that at least some of
petitioner’s installment payments were made before March 13,
2000, when petitioner’s 1987, 1990, and 1991 liabilities became
subject to an installment agreement. Clearly, respondent did not
err by applying these pre-March 13, 2000, installment payments to
years other than 1987, 1990, and 1991. Respondent’s records
indicate that ultimately petitioner received credit for 31
payments of approximately $750 each, some of which were in fact
10 In his petition filed in docket No. 24528-04L, petitioner
alleges that his installment payments totaled $27,000. In his
pretrial memorandum, petitioner states that he made installment
payments totaling “more than $24,000”. On opening brief,
petitioner asserts that his installment payments totaled $29,503.
On reply brief, petitioner asserts that his installment payments
were “$27,000. plus”.
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