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1991 until October 15, 1992. Petitioner and her husband made
payments regarding their 1991 tax liability as follows:
Type Amount Date
Estimated tax payment $2,000 June 18, 1991
Estimated tax payment 7,000 Sept. 18, 1991
Estimated tax payment 17,000 Jan. 18, 1992
Credit from 1990 return 15,874 April 15, 1992
Income tax withheld 2,381 April 15, 1992
Payment with extension 13,500 April 15, 1992
request
Total $57,755
On July 26, 1995, respondent mailed petitioner a notice of
deficiency for the taxable year 1991 (the notice) determining a
deficiency of $80,596 in tax plus additions to tax of $20,149
under section 6651(a) and $4,635 under section 6654.1 As of that
date, petitioner had not filed a Federal income tax return, or a
claim for a refund, for that year. Respondent did not issue a
notice of deficiency to petitioner's husband.
On October 15, 1995, petitioner and her husband mailed a
joint Federal income tax return for 1991 (the return) to the
Internal Revenue Service (IRS). The return reflected a tax
liability of $47,840, payments totaling $57,755, and an
overpayment of $9,915. On the return, petitioner and her husband
requested that $9,715 of the overpayment be applied to their 1992
1 Unless otherwise indicated, all statutory references are
to the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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