Michael L. Widner - Page 2

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               The record establishes and/or the parties do not dispute the           
               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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