Estate of Stella Adler Wilson - Page 3

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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.                                              
               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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