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account to other taxable years in which there were outstanding
and unpaid assessments. Respondent contends that there is an
underpayment of income tax for the taxable year 1980 in the
amount of $2,597 and that the reallocation of decedent's payment
was proper.
The sole issues for decision are whether decedent's
voluntary payment was a "designated" payment of her 1980 income
tax, and whether respondent's subsequent reallocation was proper.
Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years in
issue. All Rule references are to the Tax Court Rules of
Practice and Procedure. All dollar amounts are rounded to the
nearest dollar.
This case was submitted fully stipulated. The stipulation
of facts and the attached exhibits are incorporated herein by
this reference. At the time the petition was filed, decedent
resided in New York, New York.
Background
Decedent timely filed Federal income tax returns for the
taxable years 1980, 1981, and 1982. Respondent timely mailed
statutory notices of deficiency on October 14, 1986, determining
income tax deficiencies and additions to tax for decedent's 1980,
1981, and 1982 taxable years, as follows:
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