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1990 Tax Year
On September 13, 1992, respondent received petitioner's 1990
return. The return reflected a $3,209 overpayment to be applied to
petitioner's 1991 tax liability. However, the amount of the
overpayment was based on a computational error; the correct amount
of the overpayment is $1,054.24.
1991 Tax Year
Petitioner did not file a 1991 return. Accordingly, on March
15, 1993, the IRS filed a substitute 1991 return for petitioner.
The $1,054.24 overpayment from 1990 was applied to petitioner's
1991 tax liability.
On October 30, 1995, the IRS made a $35,957 tax assessment
for 1991. The IRS gave petitioner credit for $37,433 in withheld
taxes.
Petitioner elected to receive a refund in the amount of
$2,530.24 ($37,433 + $1,054.24 = $38,487.24; $38,487.24 - $35,957
= $2,530.24) with regard to 1991, which was mailed to petitioner on
April 27, 1998, with interest.
1992 Tax Year
On April 15, 1993, petitioner requested an extension of time
to October 15, 1993, to file his 1992 return.
Petitioner did not file a 1992 return. On June 5, 1995, the
IRS filed a substitute 1992 return for petitioner from payor
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