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indicated above, the Hunters’ tax return does not list education
benefits as an item of income. The only item identified in the
return pertaining to education is the unexplained $3,000
deduction that the Hunters claimed for tuition and fees. Other
categories of income were identified as included in the
$233,862.08 of gross income reported on the tax return, and
Mr. Hunter’s trial testimony on this point did not claim any
error in his reporting of income. Thus, any education benefits
that Mr. Hunter received have no effect on the deficiency.
Respondent’s determination with respect to the deficiency is
sustained.
2. The Credit Claimed Against the Tax for 2002
Mr. Hunter argues that respondent has failed to credit his
account properly for tax payments he made. Mr. Hunter’s sole
contention in this regard is that the abated tax assessment of
$135,924.49 from 2001 represents a tax payment that applies to
2002.
Assessment is a term used to describe the formal act of
recording on the records of the Internal Revenue Service a tax
liability that has been reported on a tax return, sec.
6201(a)(1), or that otherwise has become assessable, sec.
6213(b), (c), and (d); see sec. 6203. Before assessing a
deficiency, the Commissioner generally must issue to the taxpayer
a notice of deficiency. Sec. 6213(a); Meyer v. Commissioner, 97
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