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.
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