Astrida Terauds - Page 13

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          1    Respondent rounded off this amount to $3,957; however, since           
          the prepayments claimed by petitioner totaled $3,955.86, the                
          correct rounded off figure should be $3,956.  It follows that the           
          adjustment should be $2,883 instead of $2,884.                              
               At trial, respondent's examining agent testified that the              
          above table reflected two adjustments in the prepayments claimed            
          by petitioner on her return:  (1) Respondent increased                      
          petitioner's withheld taxes from $1,055.97 claimed on her return            
          to $1,073 to reflect an additional $17 in taxes withheld on                 
          petitioner's dividend and interest income that she had not                  
          claimed on her return, and (2) the $2,899.89 levy that was                  
          claimed by petitioner on her return as a payment was not allowed.           
          Because of these adjustments, $2,884 of the prepayments claimed             
          by petitioner was disallowed.  The agent further testified that,            
          subsequent to the filing of petitioner's 1987 return, respondent            
          applied the $2,899.89 to payment of an unpaid 1989 tax assessment           
          against petitioner.                                                         
               Petitioner contends that the $2,899.89 should be applied               
          toward her 1987 tax liability, as she directed on her 1987                  
          return, and that the 1987 deficiency should be reduced                      
          accordingly.  Petitioner also claims that the $2,884 disallowed             
          payment in the notice of deficiency represents another levy by              
          respondent on another of her bank accounts, and that this $2,884            
          levy should also be applied to her 1987 tax liability or                    
          otherwise credited or refunded to her.                                      

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