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American Express stock and had more than enough left over after
his margin loan to pay his 2000 tax liability in full and have
$100,000 in addition. Now, petitioner said, the net proceeds of
a sale would not be enough to pay the liability in full.
Petitioner and Krogue then discussed the possibility of an
arrangement with the liability being paid at the end of the year.
Petitioner then spoke with Rogers that same day. Petitioner
explained to Rogers petitioner’s impression that an installment
plan was possible, that he had a tentative agreement with Krogue
for an installment plan, and that if petitioner had known an
installment plan was not an option, then he would have made
different decisions regarding asset management. Rogers agreed to
reconsider petitioner’s proposal for an installment plan.
Petitioner telephoned Rogers on May 10, 2002. Rogers told
petitioner that Krogue would call petitioner with the details of
a 1-year installment plan that would be offered to petitioner.
Krogue telephoned petitioner on May 17, 2002, and left a message.
Petitioner telephoned Krogue on May 20, 2002, and left a message.
Krogue telephoned petitioner on May 21, 2002, regarding the
monthly installments and the total amount due. They agreed to
$400 monthly installment amounts for 11 months with the balance
due on the 12th month, but they did not agree on the total amount
due. Specifically, they disagreed about the interest and
penalties that had accrued since Krogue first received
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