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116 T.C. 60, 62 (2001).
The record in this case includes Form 4340 with respect to
each of petitioner’s taxable years 1984, 1985, 1987, and 1990 and
respondent’s statement of petitioner’s account with respect to
his taxable year 1986. Although as reflected in those forms and
that statement respondent made numerous and various corrections,
including so-called reversals, to petitioner’s accounts with
respect to his taxable years 1984, 1985, 1986, and 1987, we have
been able to reconcile all of the entries therein. Except for
respondent’s concession regarding petitioner’s taxable year 1987,
see supra note 4, on the record before us, we are unable to find
that respondent has not accounted for all of the payments that
petitioner made to the IRS with respect to his taxable years
1984, 1985, 1986, 1987, and/or 1990. Nor are we able to find on
the instant record that petitioner made an overpayment with
respect to any of his taxable years 1984, 1985, and 1986 for
which respondent has not accounted and which respondent should
have applied against petitioner’s liability for each of his
taxable years 1987 and 1990.
Based upon our examination of the entire record before us,
we find that, except for respondent’s concession regarding
petitioner’s taxable year 1987, see supra note 4, petitioner has
not paid the liability for each of his taxable years 1987 and
1990 that respondent is now attempting to collect.
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