- 3 - Year Return Date Tax Withholding Overpayment 1987 5/11/95 $5,515 $7,208 $1,693 1988 5/13/95 5,366 10,328 4,952 1990 1/15/96 5,564 6,919 1,355 1990 2/26/96 6,709 6,919 210 1990 3/15/96 5,942 6,919 977 1991 5/15/95 2,321 3,039 718 1992 5/16/95 0 2,563 2,563 The parties agree that if respondent prevails on the issues as stated below, the revised deficiencies and additions to tax will be as follows: Addition to Addition Statutory Deficiency/ Tax to Tax Year Deficiency (Overpayment) Sec. 6651(a) Sec. 6654 1987 $ 5,515 ($1,693) $ 0 $ 0 1988 5,366 (4,952) 0 1990 12,328 5,409 1,352 305 1991 2,321 (718) 0 0 1992 4,114 1,551 388 55 Petitioners concede that the overpayments are barred by section 6511(b)(2)(B). We must decide the following issues: (1) Whether petitioners are required to include, as ordinary income, the entire distribution of $25,313.22 received by JamesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011