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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.
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Last modified: May 25, 2011