Astrida Terauds - Page 12

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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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