- 9 - herein, a deficiency is the amount of income tax imposed by the Internal Revenue Code that exceeds the amount shown as the tax by the taxpayer on his return (if a return was filed). Thus, payments made by a taxpayer, such as the $750 payment, do not serve to reduce the "deficiency" within the meaning of section 6211(a). Cf. sec. 6211(b)(1). Parenthetically, we take note of the fact that respondent has acknowledged petitioner's $750 payment, and that such amount will serve to reduce pro tanto the amount of petitioner's ultimate out-of-pocket liability. Finally, petitioner has raised other arguments that we have considered in reaching our decision. To the extent that we have not discussed these arguments, we find them to be without merit. To reflect our disposition of the disputed issue, as well as petitioner's concessions, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011