- 5 -
plus the amount applied from the 1999 return.3 On the 2000
return, he claimed an overpayment of $3,268.22 and directed that
it be applied to his 2001 estimated tax.
Although petitioner reported payments totaling $6,000 for
1999, in fact he made payments totaling $6,600 and had an
overpayment of $3,377 ($3,223 - $6,600) in 1999. Respondent did
not apply that overpayment to petitioner’s 2000 estimated tax as
petitioner directed on the 1999 return. Instead, respondent
credited, as of April 15, 2000, the $3,377 overpayment from 1999
to petitioner’s unpaid tax for 1994.4
With respect to 2000, respondent assessed a total tax of
$11,091.22, rather than the $7,437.65 petitioner reported on the
2000 return. The tax assessed was calculated on $40,350 of
adjusted gross income, $33,150 of taxable income, and $5,214 of
self-employment tax. Respondent attributed the increase in the
tax assessed over that reported on petitioner’s return to
mathematical errors on the 2000 return. As a result of
respondent’s adjustments, respondent determined that petitioner
underreported his income tax by $3,653.57 ($11,091.22 -
$7,437.65). Because respondent credited petitioner’s overpayment
3We note the tax payments so claimed correctly total
$10,715.87 ($7,938.87 + $2,777).
4The transcript of petitioner’s 1999 account shows that
petitioner’s 1999 overpayment was credited to his 1994 liability
during the 40th week of 2001. The Court takes judicial notice
that the 40th week of 2001 was the first week in October 2001.
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