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D. Petitioner’s Tax Returns for 1987-92
Petitioner filed his 1987 Federal income tax return on
October 14, 1988. On it, he claimed that he should be credited
with a $70,000 estimated tax payment which he believed had been
carried forward from the $150,000 payment. However, because
respondent had reallocated the $150,000 estimated tax payment
between petitioner and his wife as described above, respondent
disallowed petitioner’s carryover of the $70,000 credit from the
$150,000 payment.
Petitioner filed tax returns for 1988 through 1992 on which
he carried forward estimated tax payments as follows:
Year Claimed estimated tax payments
carryforward
1988 $62,592
1989 62,592
1990 52,799
1991 52,799
1992 45,314
Respondent disallowed petitioner’s carryovers of estimated
tax payments to tax years 1988, 1989, 1991, and 1992 because
respondent had reallocated most of the $150,000 tax payment to
petitioner’s wife, leaving nothing for petitioner to carry
forward to those years. Respondent assessed additional taxes for
petitioner for 1989 on September 14, 1992.
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