Estate of Stella Adler Wilson - Page 12

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          $89,410--the exact amount of the 1980 income tax deficiency                 
          determined in the deficiency notice.  Also, under the same date,            
          the same transcript reflects as a "Designated Interest Payment"             
          the amount of $95,916.67.  Decedent's total payment, which                  
          appears to have been motivated by Newman's letter to his tax                
          clients, was in conformity with the provisions of Rev. Proc. 84-            
          58, supra, which deals extensively with procedures for taxpayers            
          to make remittances to stop the running of interest on                      
          deficiencies.  Rev. Proc. 84-58, supra section 5.03, 1984-2 C.B.            
          at 503, states that "A taxpayer wishing to stop the running of              
          all interest must make a payment or deposit sufficient to cover             
          all accrued interest as of the date of remittance as well as the            
          entire amount of the underlying tax."  This decedent did.                   
               The record is silent as to why the IRS treated the tax                 
          payment as a "subsequent payment" while at the same time treating           
          the interest payment as a "designated" interest payment.                    
          Whatever may have been intended by the subsequent payment label             
          in the IRS records, this is merely an entry characterized by the            
          IRS, and the records to this extent are not dispositive of the              
          issue.  See Estate of Baumgardner v. Commissioner, supra at 459.            
               Nevertheless, we are satisfied that decedent effectively               
          designated her total remittance as a payment of 1980 tax and the            
          interest thereon, notwithstanding the fact that neither party has           
          located any communication from decedent to the IRS making that              

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