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April 15, 2000, the last date prescribed for the timely payment
of tax for petitioner’s taxable year 1999. See secs. 6072(a),
6151(a). Petitioner does not contend, and the record does not
establish, that on April 15, 2000, he had reasonable cause for
his failure to pay timely the tax shown in the 1999 return.
We address next petitioner’s position that he is not liable
for the increase in the 1999 addition to tax under section
6651(a)(2) that respondent assessed on May 5, 2003, and that is
attributable to the 1999 return because respondent incorrectly
calculated the amount of such increase in such addition to tax.
In this connection, petitioner alleged in the petition:
the IRS should allow credit for taxes paid [by with-
holding] when the Petitioner makes a payment [by with-
holding] not some 15 months later. Petitioner will
demonstrate monies were in the hands of the government
and unavailable to Petitioner far before they are being
credited to the Petitioners account allowing the IRS to
assess penalties * * * upon funds that it holds.
[Reproduced literally.]
As we understand it, it is petitioner’s position that any
tax withheld from wages that he received during taxable years
after his taxable year 1999 should be applied to his unpaid total
1999 liability at the time such tax was withheld. We reject any
such position. Any tax withheld from an individual’s wages is
deemed paid by the individual on the 15th day of the fourth month
following the close of the taxable year with respect to which
such tax is allowable as a credit under section 31. See sec.
6513(b)(1).
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