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on information returns received from third parties reporting
income petitioner earned during the relevant years.
On July 14, 1999, respondent received petitioner’s 1994
Federal income tax return reporting a tax liability of $4,378 and
income tax withheld of $6,137, resulting in an overpayment of
$1,759 that petitioner thereon requested be applied to his 1995
estimated tax. Respondent accepted petitioner’s 1994 return as
filed on January 23, 2000, and subsequently assessed the tax
liability reported thereon.
On July 22, 1999, respondent received petitioner’s 1995 and
1996 Federal income tax returns. Petitioner’s 1995 return
reported a tax liability of $4,087, income tax withheld of
$2,578, and an overpayment credit of $1,759 from 1994, resulting
in overpayment of $250 that petitioner thereon requested be
applied to his 1996 estimated tax. Petitioner’s 1996 return
reported a tax liability of $5,224, income tax withheld of
$3,585, and an overpayment credit of $250 from 1995, resulting in
a payment due for that year of $1,389. Attached to the 1996
return was a Form 8275, Disclosure Statement, on which
petitioner, inter alia, provided explanations with respect to his
late filing and late payment. Respondent later accepted
petitioner’s 1995 and 1996 returns as filed but did not assess
the tax liabilities reported thereon. Other than the
withholdings previously outlined, petitioner made no additional
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