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require a remittance of the balance due (as so computed) as a
condition to obtaining the extension, petitioners submitted a
check in the amount of $125,000 with the 1993 Form 4868 (the 1994
remittance). Petitioners made no additional remittances in
respect of their 1993 tax liability.
Petitioners did not file their 1993 Federal income tax
return (the 1993 return) until January 10, 2000. On the 1993
return, petitioners reported tax of $88,662, total payments of
$138,883 (consisting of the $13,883 of 1993 withholding and the
$125,000 1994 remittance), and an overpayment of $50,221.
Petitioners also filed their 1994-96 Federal income tax
returns (the 1994, 1995, and 1996 returns, respectively) on
January 10, 2000. On the 1994 return, petitioners treated the
$50,221 overpayment reported on the 1993 return as a payment in
respect of their 1994 tax liability. On the 1995 return,
petitioners treated the remaining balance of that overpayment
(i.e., the amount of the overpayment for 1993 remaining after
application thereof to their 1994 tax liability) as a payment in
respect of their 1995 tax liability. On the 1996 return,
petitioners treated the remaining balance of the overpayment
(i.e., the amount of the overpayment for 1993 remaining after
application thereof to their 1994 and 1995 tax liabilities) as a
payment in respect of their 1996 tax liability and requested that
the resulting excess amount be applied to their 1997 tax
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