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tax on the part of the person who made the overpayment. That
issue is not, therefore, before the Court, and we express no
opinion with respect thereto.
Petitioner designated the $30,000 payment which she made on
March 9, 1998, to be applied toward the deficiency for 1980, with
any excess amount to be applied toward the deficiency for the
taxable year 1981, and if any excess amount remained, to be
applied toward the deficiency for 1982. To the extent there is
an overpayment, the overpayment will be determined pursuant to
section 6512 by a decision under Rule 155.
To properly account for the $30,000 payment, the settled
issues, and what we have held in this case, a recomputation will
be necessary, and
Decision will be entered
under Rule 155.
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