- 4 -
At the time of the $31,000 remittance, petitioner had earned
about $20,000 in wages and paid $2,777.29 in withholding tax
during 1982. Respondent treated the $31,000 remittance as an
estimated payment.
During late 1979 or early 1980, petitioner invested $26,800
in an oil well, which he expected would generate income sometime
in the future. As of May 12, 1980, the oil well was found to be
"dry", and petitioner received no return on his investment.
Petitioner's 1979 through 1982 Federal income tax returns
were untimely filed on December 10, 1993, 10 or more years late.
For the year under consideration (1982), petitioner received
$36,153.99 in taxable wages for services performed. Petitioner's
untimely 1982 return reflected $36,1544 of gross and adjusted
gross income and contained a claim for a $1,000 personal
exemption, resulting in a $9,285 tax liability. Petitioner also
claimed a credit of $41,071.72 in “estimated tax payments” to be
applied toward his 1982 tax liability, which would have resulted
in a $31,786.72 overpayment claim for 1982.
The 1979 return filed by petitioner reflected a $9,251 tax
liability, $16,545.43 of tax withheld, and a claimed overpayment
of $7,294.43. Petitioner's 1980 return reflected $20,757.44 of
wage income and a $26,800 claimed loss deduction from investment
4 Respondent in the notice of deficiency and petitioner on
his 1982 income tax return rounded off the amount from $36,153.99
to $36,154.
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