Edward H. Jones, III - Page 4




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          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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