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incorporated herein by this reference. At the time the petition
was filed in this case, petitioner resided in San Diego,
California.
Petitioner did not timely file a Form 1040, U.S. Individual
Income Tax Return, for taxable years 1991, 1992, 1993, 1994,
1995, or 1997, respectively.
On April 18, 1991, petitioner made an estimated income tax
payment of $11,807 for his 1991 tax year. Respondent at some
point applied $1,589 of this amount against petitioner’s 1991 tax
liability, leaving a credit balance of $10,218, as reflected on
several IRS statements of account for 1991.
Respondent extended the filing date for petitioner’s 1991
income tax return from April 15 until August 15, 1992.
Respondent subsequently further extended the filing date to
October 15, 1992.
On December 14, 1998, respondent sent petitioner a standard
notice entitled “REQUEST FOR YOUR TAX RETURN” concerning the
respondent’s nonreceipt of petitioner’s 1991 income tax return.
At the bottom of this notice was the following:
* * * * * * *
*** YOU HAVE A CREDIT BALANCE OF $11807 ***
Please explain how you want us to handle your credit.
See the specific instructions on the enclosed Form
9358.
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