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proceeding in which the Government is seeking to collect its
delinquent taxes or file a claim therefor." Respondent does not
argue that decedent made an involuntary payment in this case.
In the same vein, if a taxpayer makes a voluntary payment
without directing application of funds, the IRS may make whatever
allocation it chooses. See Estate of Baumgardner v.
Commissioner, 85 T.C. 445, 459 (1985). However, where a taxpayer
makes voluntary payments to the IRS, he does have a right to
direct the application of payments to whatever type of liability
he chooses. See Muntwyler v. United States, 703 F.2d 1030, 1032
(7th Cir. 1983); Estate of Baumgardner v. Commissioner, supra at
459-460.
Having postulated the foregoing principles, we must now
decide whether decedent did, in fact, designate the December 31,
1986, remittance as a payment of her 1980 income tax--i.e., the
type of liability decedent chose--and if so, whether respondent
was free on July 13, 1992, to reallocate some of the 1986
payment, i.e., $32,597 thereof, to assessments for other years,
one of which--1989--was 3 years in the future at the time
decedent made her 1986 payment.
We are satisfied that decedent designated her entire
voluntary payment as a payment of income tax and interest for
1980. A transcript of decedent's IRS account for 1980 reflects,
under date of 12/31/86, as a "Subsequent Payment" the amount of
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