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1 Respondent rounded off this amount to $3,957; however, since
the prepayments claimed by petitioner totaled $3,955.86, the
correct rounded off figure should be $3,956. It follows that the
adjustment should be $2,883 instead of $2,884.
At trial, respondent's examining agent testified that the
above table reflected two adjustments in the prepayments claimed
by petitioner on her return: (1) Respondent increased
petitioner's withheld taxes from $1,055.97 claimed on her return
to $1,073 to reflect an additional $17 in taxes withheld on
petitioner's dividend and interest income that she had not
claimed on her return, and (2) the $2,899.89 levy that was
claimed by petitioner on her return as a payment was not allowed.
Because of these adjustments, $2,884 of the prepayments claimed
by petitioner was disallowed. The agent further testified that,
subsequent to the filing of petitioner's 1987 return, respondent
applied the $2,899.89 to payment of an unpaid 1989 tax assessment
against petitioner.
Petitioner contends that the $2,899.89 should be applied
toward her 1987 tax liability, as she directed on her 1987
return, and that the 1987 deficiency should be reduced
accordingly. Petitioner also claims that the $2,884 disallowed
payment in the notice of deficiency represents another levy by
respondent on another of her bank accounts, and that this $2,884
levy should also be applied to her 1987 tax liability or
otherwise credited or refunded to her.
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