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April 15, 1994, petitioner’s $12,500 payment of 1993 income tax.
In or about the 18th week of 1994, respondent posted as of
April 18, 1994, petitioner’s $8,000 payment of 1994 estimated tax.
In or about the 26th week of 1994, respondent posted as of
June 21, 1994, petitioner’s $8,000 payment of 1994 estimated tax.
On August 17, 1994, respondent received from petitioner and
Evalyn a Form 26883, Application for Additional Extension of Time
To File U.S. Individual Income Tax Return, asking that the time for
filing their 1993 tax return be extended to October 15, 1994.
Respondent approved this request.
In or about the 39th week of 1994, respondent posted as of
September 20, 1994, petitioner’s $8,000 payment of 1994 estimated
tax.
In or about the 5th week of 1995, respondent posted as of
January 19, 1995, petitioner’s $8,000 payment of 1994 estimated
tax.
In or about the 8th week of 1995, respondent posted as of
April 15, 1993, petitioner’s and Evalyn’s $16,571.20 claimed 1992
overpayment as a payment of 1993 estimated tax. See infra note 4
and related text for later modification.
In or about the 18th week of 1995, respondent posted as of
April 15, 1995, petitioner’s $3,000 payment of 1994 income tax.
3The stipulation states that the document is Form 2868. The
document itself, a Form 2688, plainly is what the parties intended
to describe, and we so interpret the stipulation. See, e.g.,
Jasionowski v. Commissioner, 66 T.C. 312, 318 (1976).
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