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applied those amounts to satisfy liabilities for other taxable
years in which unpaid assessments were pending, as follows:
Amount Amount of Original Date of Original
Year Transferred Assessment Assessment
1978 $1,800 $7,408 05/14/79
1984 236 6,662 12/02/85
1989 30,561 23,130 02/03/92
The transfer in the amount of $30,561 from decedent's
account for the taxable year 1980 resulted in an overpayment for
the 1989 taxable year. Respondent issued a refund for the 1989
taxable year on April 19, 1993, in the amount of $12,376, of
which $1,163 was interest. The refund appears to have resulted
from abatement of interest and penalties made after the $30,561
reallocation from 1980 in 1992, plus certain other overpayment
credits transferred.
On March 9, 1998, petitioner made a payment in the amount of
$30,000. Petitioner designated this payment to be applied toward
the deficiency for the taxable year 1980. If any excess amount
remained, that amount was to be applied toward the deficiencies
for the 1981 and 1982 taxable years. The record contains no
explanation as to why petitioner made this payment, and in this
particular amount. Respondent credited $30,000 to petitioner's
account for the taxable year 1998.
Howard P. Newman (Newman), who represents petitioner in this
case, has been an attorney since January 1979. He worked for
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