IRS’ application of petitioner’s remittance after the tax liabilities has been assessed constituted a payment of that tax liability.
On December 28th, 2021 the US Tax Court reviewed and decided whether “the taxpayer has paid more than was owed, where such a determination is necessary for a correct and complete determination of whether the proposed collection action should proceed”. (per T.C. Memo. 2021-142 UNITED STATES TAX COURT Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent…