T.C. Memo. 1999-221 UNITED STATES TAX COURT ESTATE OF STELLA ADLER WILSON, DECEASED, ELEANOR SHELDON, EXECUTRIX, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 47120-86. D made a voluntary payment on Dec. 31, 1986, part of which satisfied the entire income tax deficiency as reflected in the deficiency notice for her taxable year 1980. More than 5 years later, the IRS reallocated a portion of the deficiency payment to other taxable years as to which there were outstanding assessments. The balance of D's Dec. 31, 1986, payment equaled accrued interest on the 1980 income tax deficiency. The IRS treated this amount on its records as a "designated interest payment". On Mar. 9, 1998, P, D's executor, made a voluntary payment in the amount of $30,000 which was designated to the taxable year 1980 and the 2 succeeding years. P contends that there is an overpayment of Federal income tax for the taxable year 1980 in the amount of $30,000 due to unauthorized reallocations of D's voluntary "designated" payment of tax in 1986.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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