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preceding the filing of the claim, equal to 3 years plus the
period of any extension of time for filing the return.” Sec.
6511(b)(2)(A). Petitioner filed his claim, included in his 1991
return, on February 11, 1999. He had received extensions for
filing his 1991 return totaling 6 months (one extension for 4
months and another for 2 months). Therefore, the relevant look-
back period under 6511(b)(2)(A) extended from February 11, 1999,
back to August 11, 1995.
Petitioner is not entitled to credit for an amount paid or
deemed paid outside the look-back period determined under section
6511(b)(2)(A). Petitioner’s estimated tax payment is deemed paid
on the last day prescribed for filing the 1991 return (determined
without regard to any extension of time for filing such return).
Sec. 6513(b)(2); Baral v. United States, 528 U.S. 431, 435-436
(2000). The last day for filing his 1991 return was April 15,
1992, so that is the date petitioner’s estimated payment is
deemed paid for purposes of section 6511. As such, petitioner
paid no portion of the overpayment during the applicable look-
back period. Since no amounts were paid during the look-back
period, the ceiling limitation on the petitioner’s requested
credit is zero.
III. Equitable Relief
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