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motion.
Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Las Vegas, Nevada, at the time he
filed the petition in this case.
On or about April 15, 1999, petitioner filed a Federal
income tax (tax) return for his taxable year 1998 (1998 return).
In his 1998 return, petitioner reported total income of
$51,162.71, total tax of $11,034, and claimed total credits
against the total tax reported in that return not only for
Federal income tax withheld but also for Social Security tax and
Medicare tax withheld. As a result, petitioner claimed a refund
of $927.16 in his 1998 return. Petitioner attached to his 1998
return two Forms W-2, Wage and Tax Statement, and Form 1099-MISC,
Miscellaneous Income.
On April 15, 1999, respondent credited the $927.16 refund
that petitioner claimed in his 1998 return against unpaid liabil-
ities with respect to his taxable years 1992 and 1993.
On April 15, 1999, respondent reduced the total withholding
credit that petitioner claimed in his 1998 return by $3,592,
which respondent concluded was attributable to the Social Secu-
rity tax and Medicare tax withheld that petitioner erroneously
included in the total withholding credit claimed in that return.
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