Susan L. Lesinski - Page 2

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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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