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.           
          Lauderdale, Florida.                                                        
               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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