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Petitioner and her children reside in a small rental house.
Petitioner is the sole provider. She has the use of an automobile
but does not own it.
C. Collection Action on the Unpaid 1989 Tax Liability
Petitioner claimed a filing status of married filing
separately on her 1992 and 1994-95 Federal income tax returns and
head-of-household on her 1996-98 returns. On her 1992 and 1994-98
Federal income tax returns, petitioner reported overpayments of
tax; she requested refunds of those overpayments. The overpayments
of tax were not refunded to petitioner. Instead, the overpayments
were applied to the unpaid 1989 tax liability as follows: $694.30
from 1992 (applied April 15, 1993), $991.78 from 1994 (applied
April 15, 1995), $1,030 from 1995 (applied March 18, 1996), $523
from 1996 (applied March 10, 1997), $535 from 1997 (applied March
30, 1998), and $2,001 from 1998 (applied April 15, 1999).2
In addition to the aforementioned overpayments of tax for
years subsequent to 1989, respondent’s records reflect that on
September 30, 1992, and June 16, 1998, there were payments of $200
and $408.95, respectively, applied to the unpaid 1989 tax
liability. The $408.95 payment resulted from the garnishment of
petitioner’s wages; the record is silent as to the source for the
$200 payment.
2 An overpayment of tax with interest of $111.02 from 1988
was also applied to the 1989 tax liability.
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