Bocock v. Comm'r
United States Tax Court
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
Wells, Judge:
The instant case is before the Court on respondent’s motion to enter a decision. The parties previously had represented to the Court that the case was settled and filed a stipulation of settled issues. We must decide: (1) Whether we have jurisdiction to decide whether respondent improperly credited to an earlier taxable year an overpayment that petitioners reported on their income tax return for taxable year 2002, and, (2) if we find that we have such jurisdiction, whether respondent improperly credited the overpayment. Unless otherwise indicated all section references are to the…
2Cases cited7 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Woods v. CommissionerUnited States Tax Court · 1988
- Savage v. CommissionerUnited States Tax Court · 1999
- Leon S. Malachinski v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2001
- Terry v. CommissionerUnited States Tax Court · 1988
2 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Estate of Rosen v. Comm'rUnited States Tax Court · 2008
- Bocock v. Comm'rUnited States Tax Court · 2006
- Estate of Leonard Rosen, Bernice Siegel, Special Administrator v. CommissionerUnited States Tax Court · 2008
- Estate of Rosen v. Comm'rUnited States Tax Court · 2008
- Kupersmit v. Comm'rUnited States Tax Court · 2014
4 more not listed; retrieve them via the Exa API.