- 4 - apply this overpayment to his estimated income tax for 1996. The 1996 joint income tax return reported an overpayment of $94, including $1,761 carried over from 1995. Petitioner elected to apply this overpayment to his estimated income tax for the 1997 tax year. The 1997 joint income tax return reported an overpayment of $4,203, including $94 carried over from 1996 and payments of $15,000 in estimated taxes made during 1997. Petitioner elected to apply this overpayment to his estimated income tax for 1998. Respondent applied the overpayments as directed by petitioner except in instances where the overpayments claimed by petitioner as credits could not be applied in full against petitioner’s liability because part of the carried over amounts had been deemed paid more than 3 years before the return was filed claiming a credit for that amount. OPINION The petition in this case was filed in response to a notice of determination sent after a hearing under section 6330 was conducted. Petitioner raised at the hearing his contention that the taxes that were the subject of proposed collection activity had been paid. The record is unclear as to whether any deficiency was determined against petitioner by respondent. Nonetheless, because the underlying tax liability relates to Federal income taxes, over which we have jurisdiction, we holdPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011