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petitioner and Mr. Izzi) for 1992, petitioner’s 1992 nonmaster
file transcript does not reflect a credit for the full amount of
the 1999 overpayment to the amount of the 1992 liability
respondent allocated to petitioner pursuant to section 6015(f).
The remaining $754.59 of petitioner’s 1999 overpayment is
unaccounted for. Upon the basis of the foregoing, we conclude
that respondent should have credited, as of April 15, 2000, an
additional $754.59 to petitioner to reduce the amount of the 1992
liability respondent allocated to petitioner pursuant to section
6015(f).
Respondent withheld petitioner’s overpayment for 2001.
Petitioner’s 2001 refund postdated the documents submitted to the
Court. Accordingly, neither the $1,801 listed on the notice of
determination nor the $2,182.26 reflected in petitioner’s 1992
nonmaster file transcript as petitioner’s balance as of February
28, 2002, included any credit for her 2001 overpayment.
Respondent shall credit, as of April 15, 2002, $1,422 to reduce
the amount of petitioner’s liabilities.
In addition to the application of credits to petitioner’s
1992 nonmaster file, respondent shall recalculate the interest
accrued on petitioner’s 1992 nonmaster file which reflects the
allocation of liability respondent granted pursuant to section
6015(f). Only after such a recalculation will it be possible to
determine whether petitioner has a balance due or whether there
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