- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008