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of a loss carried back from 1993, the settlement reflected an
overpayment for 1990.
The petition in docket No. 18569-93 was filed August 27,
1993. That case was set for trial, but, prior to the trial date,
the parties agreed to a settlement. A decision was entered
October 28, 1994, pursuant to a stipulation signed by
petitioners. The stipulated decision reflected a deficiency of
$10,131 for 1991.
After settlement of the cases for 1990 and 1991, disputes
between petitioners and the Internal Revenue Service (IRS)
continued as a result of collection efforts by the IRS relating
to petitioners' liabilities for 1991 and 1992. In February 1996,
petitioners prepared their Federal income tax return for 1995.
On line 12 of that return, they claimed a $99,000 business loss
and inserted "See Appendix A". Petitioners offset their combined
wages and salaries income of $124,553.62 with this alleged loss,
resulting in a claimed overpayment of $4,764. In "Appendix A",
they explained that they were claiming a loss of $49,000 that was
disallowed on their 1990 tax return and $50,000 that was
disallowed on their 1991 tax return. Attached to their 1995 tax
return was a statement dated February 25, 1996, as follows:
Please note that I have assigned the $4764.00
overpayment for 1995 to pay for the $794.00 1991-1992
ACS plan installments for the payment dates Apr. 1,
May 1, June 1, Jul 1, Aug. 1, and Sep 1, 1996. I am
sending a copy of this statement to the ACS plan office
and to Congressman Becerra's office. In the instance
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