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paid within the 3-year period immediately preceding the filing of
his 1990 Federal income tax return. Under section 6513(b)(1),
any Federal income taxes withheld by petitioner or his wife’s
employer for 1990 are considered paid to the Commissioner by
petitioner or his wife on April 15, 1991. See also Landry v.
Commissioner, 116 T.C. 60 (2001). Given that petitioner advances
no other allegation of error as to respondent’s determination,
and that the record does not otherwise disprove the
determination, we sustain respondent’s determination that he may
proceed with the proposed levy.
Decision will be entered
for respondent.
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Last modified: May 25, 2011