Eugene M. Landry - Page 3




                                        - 3 -                                         
               When he filed his returns as set forth above, petitioner               
          indicated that the overpayments claimed from withholding or                 
          carried over estimated tax from prior years should be applied to            
          the estimated tax for the following year.  The 1989 joint income            
          tax return reported an overpayment of $2,329.  Petitioner elected           
          to apply this overpayment to his estimated income tax for 1990.             
          The 1990 joint income tax return reported an overpayment of                 
          $3,074, including $2,329 carried over from 1989.  Petitioner                
          elected to apply this overpayment to his estimated income tax for           
          1991.  The 1991 joint income tax return reported an overpayment             
          of $3,568, including $3,074 carried over from 1990.  Petitioner             
          elected on his 1991 joint income tax return to apply this                   
          overpayment to his estimated income tax for 1992.  The 1992 joint           
          income tax return reported an overpayment of $544, including                
          $3,568 carried over from 1991.  Petitioner elected to apply this            
          overpayment to his estimated income tax for the 1993 tax year.              
          The 1993 joint income tax return reported an overpayment of $816,           
          including $544 carried over from 1992.  Petitioner elected to               
          apply this overpayment to his estimated income tax for 1994.  The           
          1994 joint income tax return reported an overpayment of $1,491,             
          including $816 carried over from 1993.  Petitioner elected to               
          apply this overpayment to his estimated income tax for 1995.  The           
          1995 joint income tax return reported an overpayment of $1,761,             
          including $1,491 carried over from 1994.  Petitioner elected to             






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