- 3 -
of $5,859, and an addition to tax due of $3,6204 under section
6654(a) for failure to pay estimated taxes. Petitioner made no
Federal tax deposits and had no withholding credit during 1988.
Further, petitioner did not remit a payment with the 1988 return.
On his 1989 Federal income tax return petitioner reported a
$66,742 loss. He filed with his return an IRS Form 1045,
Application for Tentative Refund, computing the net operating
loss for 1989 and electing a carryback of the loss to
petitioner's 1988 tax year. On June 11, 1990, the IRS allowed
the 1989 net operating loss carryback and applied it to
petitioner's 1988 account as of April 18, 1990. The 1989 net
operating loss reduced petitioner's 1988 income tax liability by
$19,519. After the carryback of the 1989 loss to 1988,
petitioner’s account reflected the following amounts still owing
for 1988:
$31,223.00 Income tax
5,859.00 Self-employment tax
2,177.00 Sec. 6654, Failure to pay estimated taxes
6,342.53 Sec. 6651(a)(2), Failure to pay tax
6,929.17 Interest to April 18, 1990
$52,530.70 Total
4 In an amended return, petitioner recalculated the
addition to tax under sec. 6654(a) reducing it to $2,177. For
our purposes here, the amended amount was accepted by the
Internal Revenue Service.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011