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petitioner’s case. Petitioner then spoke with Rogers and
reiterated his objections to the accrued interest and penalties.
Rogers declined to abate petitioner’s penalties and explained
that petitioner could file an appeal of this decision with the
Office of the Taxpayer Advocate.
Petitioner received the necessary forms from Krogue on May
31, 2002. He noticed that the installment payment plan required
monthly payments of $600 instead of $400. There followed a
series of missed telephone calls. On June 12, 2002, petitioner
telephoned Krogue, who agreed that petitioner should cross out
the $600 and replace it with $400, sign the forms as corrected,
and return the forms to Krogue. Krogue received the signed forms
on June 14, 2002. On June 24, 2002, petitioner received a
notification that the IRS accepted the 1-year installment
arrangement. The next day, petitioner mailed the first $400
monthly payment, which was credited to his 2000 tax account on
June 27, 2002. A 2001 overpayment of $4,343 was credited to
petitioner’s 2000 tax account as of April 15, 2002.
Petitioner continued to make his monthly installment
payments through November 2002. On December 13, 2002, petitioner
paid his remaining 2000 tax obligation in full, including
interest and penalties.
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Last modified: March 27, 2008