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2. Carryover Credit From Taxable Year 1990 to Taxable Year 1991
On their late-filed 1990 Federal income tax return,
petitioners showed a $7,631 overpayment, which they requested be
applied to their 1991 estimated tax. Consistent with this
position, on their late-filed 1991 Federal income tax return,
petitioners claimed $7,631 as “1991 estimated tax payments and
amount applied from 1990 return”.
Respondent’s certificate of assessments and payments for
petitioners’ 1990 taxable year, by contrast, shows that
petitioners overpaid their 1990 joint Federal income taxes by
only $1,028, $876 of which respondent transferred to cover
petitioners’ unpaid 1989 Federal income tax liabilities,
additions to tax, and interest. Respondent transferred a
carryover credit of the remaining overpayment of $152 from
taxable year 1990 to petitioners’ 1991 accounts. Respondent
contends that petitioners are entitled to no additional carryover
credit from 1990 to 1991.
The difference between the $7,631 overpayment claimed by
petitioners on their 1990 return and the $1,028 overpayment
reflected in respondent’s records is attributable to $6,603
claimed on petitioners’ 1990 joint Federal income tax return as
“1990 estimated tax payments and amount applied from 1989
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Last modified: May 25, 2011