Legal Opinion

Bocock v. Comm'r

United States Tax Court

Decided October 30, 2006No. 11161-05Published

Ps made certain payments before filing their 2002 tax return and intended that the payments would be applied to their 2002 taxable year. R first credited the payments to Ps' 2002 taxable year but later credited the payments to P husband's outstanding tax liability from 1978 after Ps filed their 2002 tax return on which they claimed an overpayment.

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Ps made certain payments before filing their 2002 tax return and intended that the payments would be applied to their 2002 taxable year. R first credited the payments to Ps' 2002 taxable year but later credited the payments to P husband's outstanding tax liability from 1978 after Ps filed their 2002 tax return on which they claimed an overpayment. R subsequently determined a deficiency in income tax and an accuracy-related penalty pursuant to sec. 6662(a), I.R.C., for Ps' 2002 taxable year and sent Ps a notice of deficiency. Ps timely petitioned this Court for a redetermination of the…

1Opinion of the Court

SUSAN BOCOCK AND JACK CARL RYALS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Bocock v. Comm'r

No. 11161-05

United States Tax Court

127 T.C. 178; 2006 U.S. Tax Ct. LEXIS 33; 127 T.C. No. 12;

October 30, 2006, Filed

Ps made certain payments before filing their 2002 tax return and

intended that the payments would be applied to their 2002

taxable year. R first credited the payments to Ps' 2002 taxable

year but later credited the payments to P husband's outstanding

tax liability from 1978 after Ps filed their 2002 tax return on

which they claimed an overpayment. R subsequently determined a

def…

2Cases cited8 opinions

  1. Naftel v. CommissionerUnited States Tax Court · 1985
  2. Woods v. CommissionerUnited States Tax Court · 1988
  3. Savage v. CommissionerUnited States Tax Court · 1999
  4. Leon S. Malachinski v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2001
  5. Terry v. CommissionerUnited States Tax Court · 1988

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