-5-
1988 Tax Year
For his 1988 tax year, petitioner made two estimated tax
payments of $2,500 each on June 17 and September 19, 1988. On
April 15, 1989, petitioner requested (1) an extension of time (to
August 15, 1989) to file his 1988 tax return, and (2) remitted
$8,000 therewith.
Petitioner did not file a 1988 return. On March 1, 1993, the
IRS filed a substitute 1988 return for petitioner based on payor
information documents. The parties have stipulated that
petitioner's tax liability for 1988 is $5,859.
No overpayment from 1987 was applied to petitioner's 1988 tax
obligation. The $13,000 ($5,000 estimated tax payments plus $8,000
remitted on April 15, 1989) was noted on the 1988 IRS records for
petitioner but was not applied to his 1988 tax obligation.
1989 Tax Year
On September 15, 1989, petitioner made a $7,500 estimated tax
payment toward his 1989 tax year. On April 15, 1990, petitioner
(1) requested an extension of time to file his 1989 return, and (2)
remitted $1,000 therewith.
On March 8, 1993, the IRS filed a substitute 1989 return for
petitioner. On April 30, 1995, the IRS received a 1989 return from
petitioner. On October 30, 1995, the IRS made a $14,261 tax
assessment for 1989.
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