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whether petitioner is liable for the additions to tax under
section 6651(a)(2) for failure to timely pay the 1991, 1992, and
1996 tax liabilities. Petitioner resided in Maitland, Florida,
at the time the petition was filed.
Background
1991, 1992, and 1996 Federal Income Tax Returns
Petitioner filed his 1991 return on January 6, 1999.
Respondent assessed petitioner’s reported tax due of $2,216 on
March 15, 1999. The 1991 return bears a date stamp of “February
10, 1993" next to the signature line on the return.
Petitioner filed his 1992 return on September 28, 1998.
Respondent assessed petitioner’s reported tax liability of $817
on November 30, 1998. The 1992 return is not a part of the
record.
As to the 1996 taxable year, petitioner filed Form 4868,
Application for Automatic Extension of Time to File U.S.
Individual Income Tax Return, on April 15, 1997, and remitted a
payment of $1,000 to respondent. Petitioner filed his 1996
return on April 23, 2000, and respondent assessed the reported
tax due of $1,575 on November 6, 2000. Petitioner made no
additional payments for the 1991, 1992, and 1996 taxable years
because he contended that an overpayment from 1987 applied to the
tax liabilities for those years.
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