Doreen Boyd - Page 8

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          amount of $285.22, dated April 14, 1994, that she claims                    
          constituted a payment toward her assessed deficiencies for 1988             
          and 1990.  However, the record establishes that on May 26, 1994,            
          respondent credited petitioner’s 1991 tax account with a payment            
          in the amount of $285.22.  There is no indication that petitioner           
          designated the $285.22 amount as a payment toward her 1988 or               
          1990 account.  Respondent was therefore under no obligation to              
          apply the $285.22 payment toward petitioner’s 1988 or 1990                  
          taxable years.  See Amos v. Commissioner, 47 T.C. 65 (1966).                
               Petitioner presented no other evidence of payments toward              
          her accounts for the years in issue and therefore we find that no           
          such payments were made.                                                    
               Regarding petitioner’s claim that respondent should have               
          applied a portion of her overpayments for subsequent tax years to           
          her 1988 and 1990 tax liabilities, petitioner’s claim is without            
          merit.  Respondent was authorized, pursuant to section 6402(a),             
          to credit the amount of any overpayment against any of                      
          petitioner’s tax liabilities.  The record in this case indicates            
          that respondent applied overpayments from petitioner’s subsequent           
          tax years to petitioner’s assessed liabilities for a number of              
          years, including the years in issue.  Respondent was authorized             
          under section 6402(a) to apply petitioner’s refunds against an              
          outstanding liability for any taxable year and was under no                 

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