Krugman v. Commissioner
United States Tax Court
P filed his 1985 Federal income tax return on Oct. 27, 1992. In July 1993, P signed an installment agreement for 1985. From August 1993 to March 1995, R sent 19 monthly payment notices for 1985 to P which erroneously said they included interest. The notices also said that P was reducing his unpaid balance for 1985 to zero by making the monthly payments. P timely paid the installments.
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P filed his 1985 Federal income tax return on Oct. 27, 1992. In July 1993, P signed an installment agreement for 1985. From August 1993 to March 1995, R sent 19 monthly payment notices for 1985 to P which erroneously said they included interest. The notices also said that P was reducing his unpaid balance for 1985 to zero by making the monthly payments. P timely paid the installments. On Aug. 9, 1995, R sent a notice to P which said that he owed $ 6,019.10 for 1985. This notice was inconsistent with the 19 installment payment notices R had sent to P. P believed the Aug. 9, 1995, notice was in…
1Opinion of the Court
Colvin, Judge:
On April 10, 1997, respondent issued a final determination partially disallowing petitioner’s claim to abate interest. Petitioner timely filed a petition under section 6404(g)1 and Rule 280.
The issues for decision are:(1) Whether we have jurisdiction to decide: (a) Whether petitioner is liable for additions to tax or penalties other than those which he paid in installments, (b) whether respondent’s levy was improper, and (c) whether petitioner may offset his 1985 income tax liability with a refund from 1995. We hold that we do not.(2) Whether respondent’s denial of petitioner’s…
2Cases cited2 opinions
- Meyer v. CommissionerUnited States Tax Court · 1991
- Banat v. CommissionerUnited States Tax Court · 1997
3Cited by26 opinions
- Downing v. Comm'rUnited States Tax Court · 2002
- Henderson v. United StatesDistrict Court, E.D. Wisconsin · 2000
- Yuen v. United StatesDistrict Court, D. Nevada · 2003
- Allcorn v. CommissionerUnited States Tax Court · 2012
- Braun v. Comm'rUnited States Tax Court · 2005
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