- 4 -
plan for an estimated $120,000 remaining obligation on his 2000
income tax. Petitioner was told to submit a Form 433-F,
Collection Information Statement, with a proposed payment plan
and supporting justification. Petitioner submitted his proposed
installment plan, his Form 433-F, and his explanation for
requesting an installment plan (hereinafter sometimes
collectively referred to as the first installment proposal) to
the IRS on or about August 4, 2001.4 In the first installment
proposal petitioner proposed to pay the principal of $130,0005
over 8 years, in four $32,500 biennial installments, beginning
September 1, 2003. He proposed to make monthly interest payments
at a 7.5-percent annual rate on the unpaid principal beginning
September 1, 2001. The monthly interest payments would be $812
for the first 2 years.
4 On May 17, 2003, petitioner sent a letter to the IRS
penalty appeals coordinator, in Fresno, Calif., to which he
attached several documents, including the following: (1)
Petitioner’s appeal statement and facts (in which he states that
the first installment proposal was included in his 2000 tax
return, received by the IRS on “8/2/2001”), and (2) petitioner’s
stipulated IRS communication log (in which he states that he sent
the first installment proposal on “8/4/2001”). We assume the
contemporaneously kept log is probably more accurate than later
created narratives, and we have made our findings accordingly.
In this instance, the difference in dates between the statements
does not affect our conclusions.
5 The record does not explain the difference between the
$130,000 stated principal and the $126,403 shown as the amount
owed on his tax return. See supra table 1.
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