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In or about the 19th week of 1995, respondent posted as of
April 15, 1995, petitioner’s $1,000 payment of 1995 estimated tax.
In or about the 27th week of 1995, respondent posted as of
June 23, 1995, petitioner’s $8,000 payment of 1995 estimated tax.
On or about August 21, 1995, respondent received from
petitioner and Evalyn a Form 2688 (see supra note 3) asking that
the time for filing their 1994 tax return be extended to October
15, 1995.
In or about the 30th week of 1995, respondent posted as of
September 20, 1995, petitioner’s $8,000 payment of 1995 estimated
tax.
On or about October 18, 1995, respondent received from
petitioner and Evalyn an unsigned 1992 tax return, consisting of a
Form 1040 and a Form 6251, relating to alternative minimum tax for
individuals. Petitioner and Evalyn sent this document by certified
mail. The Form 6251 shows an alternative minimum tax of $221.07,
as does the Form 1040, line 48. The Form 1040 shows a direction by
petitioner and Evalyn that their 1992 overpayment, in the amount of
$16,350.134 be applied to their 1993 estimated tax. On December
22, 1995, petitioner sent to respondent a follow-up letter attached
to which is an unsigned 1993 tax return consisting of a Form 1040
without any attachments. Petitioner sent this document by
4The original claimed overpayment (discussed supra),
$16,571.20, less $221.07, equals $16,350.13.
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