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of $12,886.50, a difference of $6,249.58. Of this difference,
$622.94 is easily explained. The record contains copies of the
Hansens' returns from 1979 through 1988 as well as transcripts of
account for each of those years. The difference of $622.94 has
its genesis in the claimed overpayment from 1979 to 1980, which
petitioner contends is $11,497.18, while the transcript of
account shows the credit applied from a prior period to 1980 as
$10,874.24. This discrepancy continues to appear in the
computation of estimated tax carryover for each taxable year
through 1988.
Section 6214(b) provides:
The Tax Court in redetermining a deficiency in income
tax for any taxable year * * * shall consider such
facts with relation to the taxes for other years * * *
as may be necessary correctly to redetermine the amount
of such deficiency, but in so doing shall have no
jurisdiction to determine whether or not the tax for
any other year * * * has been overpaid or underpaid.
Petitioner's dispute with respondent over the amount of
overpayment credit from 1987 to 1988 is a continuation of a
dispute beginning in 1979. The fact remains that respondent's
records reflect an overpayment credit from 1987 to 1988 in the
amount of $ 12,886.50, and petitioner has not shown that amount
to be any larger. Accordingly, we reject petitioner's contention
in this regard.
The balance of the discrepancy stems from various
calculations arising out of the deficiency in the Hansens' income
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