Michael P. Georges v. U.S. Internal Revenue Service

This case presents the question of whether a taxpayer may elect to credit an overpayment of taxes to the estimated tax for the subsequent year but later, after the time for filing has expired, file an amended return and claim a refund of the overpayment.

On June 19, 1986, Michael P. Georges filed tax returns for the tax years of 1977 through 1985. In each return for those years, Georges elected to credit all over-payments of tax to the succeeding year. Thus, on his 1985 tax return, he claimed a $13,282 overpayment which he elected to credit to his 1986 estimated tax. On August 1, 1989, Georges…