Edward H. Jones, III - Page 10




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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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