Hays v. Commissioner

During each of the taxable years in controversy decedent paid certain sums on account of estimated tax. He also paid amounts in respect of deficiencies in income tax of prior taxable years. The total payments in each year exceed 80 per cent of the total income tax due, but the amounts paid as estimated tax alone are less than 80 per cent of the income tax liability for each year. Held: (1) The duty to pay deficiencies due from prior tax years and that of making current payments on estimated tax are distinct. Payments on account of such deficiencies cannot be treated as part of the amount paid…