- 3 -
expenses under section 212, relating to rental property, which
was not allowed by respondent; (4) whether petitioner, for the
year 1987, is entitled to apply, as partial payment of the tax
shown as due and owing on her return, the amount of $2,899.89
held by respondent for her account, which was received by
respondent pursuant to a levy, and whether petitioner is entitled
to an additional credit for the proceeds of a separate levy that
is not shown on respondent's transcript of account; (5) whether
petitioner is entitled to credits or refunds for overpayments of
her 1986 and 1987 taxes; and (6) whether petitioner is liable for
the additions to tax under section 6651(a)(1) for 1986 and 1987.3
Some of the facts were stipulated. Those facts, with the
annexed exhibits, are so found and are incorporated herein by
reference. At the time the petition was filed, petitioner's
legal residence was Long Beach, New York.
During the years at issue, petitioner was a systems engineer
for the Sperry Rand Corp. Her 1986 Federal income tax return was
filed on April 15, 1992, and her 1987 return was filed on March
4, 1992.
Because there are several issues involved in this case, we
have combined our findings of fact and opinion with respect to
3
For 1986, respondent disallowed itemized deductions of
$3,011, consisting of mortgage interest and property taxes.
These disallowed amounts were allowed as deductions for rental
expenses. Petitioner does not challenge the characterization of
these items as rental expenses.
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