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tell from the notice of determination how respondent arrived at
the $1,801 amount owed by petitioner. Accordingly, we shall
review petitioner’s 1992 liability step by step.
As an initial matter, we agree with respondent’s computation
contained in petitioner’s 1992 nonmaster file transcript of the
amounts allocable to petitioner for 1992 after granting partial
section 6015 relief. Accordingly, respondent was correct to
compute the amount of tax and the addition to tax owed by
petitioner as $3,211 and $374.47, respectively.
On April 15, 1999, respondent applied petitioner’s 1998
overpayment as follows: $1,921.62 to the tax allocated to
petitioner for 1992 and $949.38 to petitioner’s employment tax
liabilities.8
Respondent claims that he applied petitioner’s 1999
overpayment of $3,268 to the amount of the 1992 liability
respondent allocated to petitioner pursuant to section 6015(f).
On April 15, 2000, respondent applied petitioner’s 1999
overpayment to petitioner’s 1992 nonmaster file transcript as
follows: $1,998.12 to the tax allocated to petitioner for 1992
and $515.29 to the addition to tax allocated to petitioner for
1992. This totals only $2,513.41. Although the Form 2866
reflects a $3,268 credit for 1999 to the total liability (of
8 Petitioner’s employment tax liabilities are not before
the Court.
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Last modified: May 25, 2011