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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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