Keith Lee Wilson - Page 8

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          Nevertheless, we are able to ascertain from the record (sketchy as          
          it is) that petitioner overpaid his 1988 taxes and underpaid his            
          1992 taxes.                                                                 
               For 1988, the parties stipulated that (1) petitioner made              
          estimated tax payments of $5,000, and remitted $8,000 with his              
          request for an extension of time to file his 1988 return, and (2)           
          petitioner's tax liability is $5,859.  Petitioner contends that in          
          addition to the $13,000 he sent to the IRS, he is entitled to the           
          benefit of overpayments from prior years (totaling $20,127) for             
          which he was not properly given credit, resulting in an aggregate           
          1988 overpayment of $27,268.2                                               
               For tax year 1992, petitioner contends that he had a $25,7393          
          carryover payment from 1991 for which he was not properly given             
          credit. Consequently, petitioner claims he is entitled to a                 
          $23,8084 refund for 1992 ($39,368.97 + $25,739 = $65,108.97;                
          $65,108.97 - $41,300 = $23,808.97).                                         
               Pursuant to section 6512(b)(1), we have jurisdiction to                
          determine the existence and amount of any overpayment of tax to be          
          credited or refunded for years that are properly before us.  An             


               2    On brief, petitioner stated that he is due a refund for           
          1988 in the amount of $28,268 but made a $1,000 mathematical                
          mistake.                                                                    
               3    We are unable to ascertain how petitioner determined              
          the $25,739 carryover payment.                                              
               4    On brief, petitioner (making another mathematical                 
          mistake) stated that his 1992 refund should be $24,135.                     




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