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The fourth issue is whether petitioner is entitled to direct
the payment of a portion of the tax shown on her 1987 return by
the application of levied funds held by respondent for
petitioner's account. In addition, petitioner claims further
credit for an additional levy by respondent that is not reflected
on respondent's transcript of petitioner's account.
The Federal income tax return filed by petitioner for 1987
showed a tax of $4,379. As shown on the return, petitioner paid
that tax in the following manner:
Federal income taxes withheld $1,055.97
Levy on bank account 2,899.89
$3,955.86
Amount paid with return 423.14
Total $4,379.00
Petitioner's return included a footnote referencing the levy
shown above as follows: "Dime Bank ($901.11) and Crossland
Savings ($2,899.89)".
In the notice of deficiency, respondent made the following
adjustments to the payment amounts shown above, with the
following explanation:
Adjustment: FEDERAL WITHHOLDING
1987
PER RETURN: + 3,9571
CORRECTED: + 1,073
ADJUSTMENT: + 2,884
Explanation
Your withholding credit(s) was/were adjusted to reflect
amount(s) shown on your Form(s) W-2.
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