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year 1990 and one for the taxable year 1991. As of May 18, 1994,
petitioner had not filed income tax returns or claims for refund
for taxes withheld for either of the tax years 1990 or 1991.
During the period from May 18, 1992, through May 18, 1994,
petitioner made no payments of tax and received no credits for
withheld taxes or other credits for the tax years 1990 and 1991.
Petitioner filed her petition with this Court on August 22, 1994.
Subsequently, on October 20, 1994, petitioner filed her Federal
individual income tax returns for the tax years 1990 and 1991.
The parties now agree that petitioner's total Federal income
tax liabilities for the 1990 and 1991 taxable years are
$16,672.62 and $17,121.04, respectively. As a result of Federal
income tax withholding from her wages, petitioner paid taxes of
$18,425 and $18,125 during the taxable years 1990 and 1991,
respectively. These amounts are deemed to have been paid on
April 15, 1991 and 1992, respectively. Accordingly, petitioner
overpaid her 1990 and 1991 Federal individual income taxes by
$1,752.38 and $1,053.96, respectively.
Petitioner claims that she is entitled to a determination of
overpayment of her 1990 and 1991 Federal individual income taxes,
and that the overpayments should be refunded to her. Respondent
contends that petitioner is not entitled to a determination of
overpayment because of the jurisdictional limitations of sections
6511 and 6512(b).
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