Estate of Stella Adler Wilson - Page 15




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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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