- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011