Martin v. Commissioner, IRS

OPINION

Alfred J. Martin appeals from the tax court’s determination that a $50,000 tax payment that he made in 1996 was credited properly by the Internal Revenue Service (IRS) to his tax liability for 1980 rather than for 1981 and 1982. Finding no error, we affirm.

I

Martin was married to Amilu Rothhammer during 1980; they were divorced in 1981. Martin and Rothhammer are both physicians. Prior to 1980, they bought a limited partnership interest in Winchester Oil & Gas, one of the “Manhattan group” of approximately 20 partnerships. (A. at 16.) 1 The Manhattan partnerships were involved in a group…