-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.
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