- 4 - unable to recognize in the year realized due to the limitation on capital losses set forth in section 1211(b). For each year in issue, petitioner's income tax liability, tax withheld, overpayment, and the amount of the overpayment that was attributable to worthless securities and oil and gas ventures are as follows: 1986 1989 1990 1991 1992 Tax liability $5,740 $7,879 $10,481 $18,917 $5,352 Amounts withheld by GE 13,169 12,274 12,757 14,321 --- Pension trustee --- --- --- 3,950 4,781 Interest payers --- 201 424 740 1,824 Total 13,169 12,475 13,181 19,011 6,605 Overpayment 7,429 4,596 2,700 94 420 Attributable to Worthless securities 960 840 845 94 420 Oil & gas ventures 4,558 3,077 2,700 94 1,253 Discussion Respondent concedes that petitioner is entitled to refund of $840, $845, $94, and $420 for the respective years from 1989 through 1992. Respondent argues that petitioner is not entitled to a refund of any other overpaid amount because: (1) The amounts paid for 1986 were paid by petitioner more than 7 years before the issuance of the notice of deficiency and (2) the disputed amounts paid for each other year were paid by petitioner more than 2 years before the issuance of the notice of deficiency, and none of these amounts were attributable to items listed in section 6511(d) that would extend this period beyondPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011