-8- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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