- 3 - 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:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011