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monthly $350 payment at this point, but, petitioner’s notes
indicate: “I make no payment thinking I will be paying per a
formal agreement in the near future.”
On April 4, 2002, Krogue reviewed the Internal Revenue
Manual provisions regarding installment payment plans and
concluded that petitioner could fully pay his 2000 tax obligation
and so did not qualify for an installment payment plan. Krogue
spoke with petitioner on April 24, 2002, and explained that she
could not accept petitioner’s installment plan because petitioner
had assets sufficient to fully pay his 2000 tax obligation.
Krogue agreed to speak with her supervisor, Craig Rogers
(hereinafter sometimes referred to as Rogers), about the matter
and, if Rogers agreed with Krogue’s conclusion, then petitioner
could speak with Rogers. Rogers agreed with Krogue that
petitioner had assets sufficient to fully pay his 2000 tax
obligation and, consequently, petitioner’s request for an
installment payment plan should be denied.
On May 1, 2002, Krogue told petitioner that Rogers agreed
with her that petitioner was not eligible for an installment
payment arrangement. She advised petitioner that he could
discuss the matter with Rogers. Petitioner complained about the
delay in receiving this ruling; he told Krogue that, if Krogue
had told him that he was ineligible when they first began to work
together on this payment problem, then he could have sold his
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Last modified: March 27, 2008