T.C. Memo. 1998-319
UNITED STATES TAX COURT
ROBERT K. STEWART, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4901-97. Filed September 8, 1998.
Robert K. Stewart, Jr., pro se.
Kay Hill, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Petitioner petitioned the Court to redetermine
respondent's determination of a $17,287 deficiency in his 1990
Federal income tax and a $4,297 addition thereto under section
6651(a)(1). Following concessions, the only issue left to decide
is whether we are authorized to determine any overpayment from
1989 that petitioner may credit to his 1990 Federal income tax
liability. We hold we are not. Section references are to the
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