- 5 -
to as Marian), husband and wife, resided in New Windsor,
Maryland; their collective net worth did not exceed $2 million.
At all relevant times, John was self-employed as a dentist,
and Marian was employed as the office administrator for John’s
dental practice. Marian is also a licensed and certified speech
and language pathologist.
Petitioners filed joint Federal income tax returns for 1979,
1981, and 1982. They made their tax returns on the basis of the
calendar year. Petitioners paid the entire amount of the tax
liabilities shown on each of their tax returns for 1979, 1981,
and 1982 before the respective tax return was required to be
filed. In particular, petitioners’ 1979 tax return was filed on
or before April 15, 1980, and the $19,821.50 liability shown
thereon was paid in full by a combination of withheld taxes
($1,135.20), estimated tax payments ($18,000), and payment with
the tax return ($686.30). Petitioners’ 1981 tax return was filed
on or before April 15, 1982, and the $6,277 liability shown
thereon was paid in full by a combination of withheld taxes
($1,135.20), estimated tax payments ($11,500), and other
refundable credits ($1,095). On June 7, 1982, respondent
refunded the $7,453.20 overpayment claimed on the 1981 tax
return. Respondent did not pay interest on this refund for 1981.
Petitioners’ 1982 tax return was filed on or before April 15,
1983, and the $4,919 liability shown thereon was paid in full by
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011