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