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Thereafter, on April 15, 1994, petitioner requested an extension
of time to file his 1993 return, which request was granted.
Petitioner made an additional $7,000 payment with that request.
Thus, petitioner made payments for 1993 in the total amount of
$38,000.
Petitioner filed his 1993 return on April 28, 1997, and
reported tax thereon in the amount of $27,869. Based on his
reported tax and his total payments, petitioner claimed an
overpayment for 1993 in the amount of $10,131 (i.e., $38,000 -
$27,869). Respondent applied the $10,131 overpayment to
petitioner's assessed tax liabilities for 1990 and 1991 as
follows:
Year Amount Applied
1990 $3,081.54
1991 7,049.46
Total 10,131.00
Petitioner's assessed tax liabilities for 1990 and 1991 included
interest and penalties.
On November 20, 1997, respondent issued a notice of
deficiency to petitioner. In the notice, respondent determined a
deficiency in petitioner's income tax for 1993 in the amount of
$5,926. Thereafter, petitioner filed a timely petition with this
Court.
Prior to trial, petitioner conceded the deficiency
determined by respondent in the notice of deficiency, and the
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