- 5 -
On September 3, 2001, the IRS assessed a $3,160.07 “Failure
to Pay Tax Penalty” (see supra note 3) and $3,307.90 of interest.
On September 10, 2001, the IRS credited petitioner’s account with
$300 “Immediate Tax Relief Credit” and assessed an additional
$178.48 of interest. On each of these dates the IRS sent a
statutory notice of balance due to petitioner.
Petitioner’s case was assigned to Revenue Officer Karen
Krogue (hereinafter sometimes referred to as Krogue) on September
28, 2001.6 On October 24, 2001, Krogue sent a letter to
petitioner stating the balance due on petitioner’s account.
Krogue and petitioner each attempted to contact the other by
telephone on November 8, 2001 (and perhaps other times), and
finally met in Krogue’s office, in Bellevue, Washington, on
November 14, 2001. At this meeting, Krogue and petitioner
discussed payment of the balance of petitioner’s 2000 tax
obligation. Krogue told petitioner that respondent’s policy was
to collect payment in full if the taxpayer had enough assets to
satisfy the tax obligation, but that installment arrangements
were possible under certain circumstances. Krogue told
petitioner that by December 14, 2001, he was to submit: A Form
433-A, Collection Information Statement for Wage Earners and
6 So stated in Revenue Officer Krogue’s stipulated case
notes. Petitioner’s response and memorandum state that his case
was assigned to Krogue on or about Sept. 24, 2001. This
difference does not affect our conclusions.
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