Perry C. Krape - Page 2
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decide whether to grant respondent’s motion. For the reasons
stated below, we shall grant respondent’s motion.
At the time he filed his petition, petitioner resided in Ft.
On April 15, 2001, petitioner filed Form 4868, Application
for Automatic Extension of Time To File U.S. Individual Income
Tax Return (application for extension). With his application for
extension, petitioner estimated that his income tax liability for
2000 was $225,000 and submitted a payment of that amount. On
October 24, 2002, petitioner delinquently filed a Form 1040, U.S.
Individual Income Tax Return (the delinquent return), for the
2000 tax year, showing a tax due of $248,805. On lines 59 and 65
of the delinquent return, petitioner erroneously entered $250,000
of 2000 estimated tax payments. On lines 66 and 67a of the
delinquent return, petitioner entered an overpayment in the
amount of $1,195 and requested a refund of that amount.
On January 30, 2003, pursuant to a request from respondent,
petitioner paid the difference between his actual estimated tax
payments for tax year 2000 of $225,000 and the tax liability he
reported on his return of $248,805 (amounting to $23,805), plus
On March 22, 2005, respondent mailed petitioner a notice of
deficiency, determining unpaid taxes, additions to tax, and
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Last modified: November 10, 2007