§6315 — Payments of estimated income tax

Section 6315 provides that "Payment of the estimated income tax, or any installment thereof, shall be considered payment on account of the income taxes imposed by subtitle A for the taxable year." (Emphasis added.) - 6 - Section 6151(a) provides that generally a person required to make a return of tax is required to pay such tax at the time and pl

On September 9, 1997, respondent assessed an income tax deficiency of.$14,445, a section 6663 penalty of $9,639, and 3Mrs. Conn f:.led a separate petition in response to the notice of deficie acy. Before ltrial the Commissioner conceded that under sec. 6315 Mrs. Conn was not liable for the deficiency, and we entered a decision reflecting the settlement. Conn v. Commissioner, T.C. Memo. 2008-186. - 4 - interest (collectively, the -1993 liability) against petitioner for '1993. Respondent, subsequ

6654.5 See also In re Ripley, 926 F.2d 440, 441-442 (5th Cir. 1991), for a brief, general discussion of the estimated tax payment procedure. Once such reported liability is paid, any excess payment constitutes an overpayment, which may be refunded to the taxpayer or applied by the Commissioner to any outstanding liability owed b

- 7 - If we find that petitioner’s $31,000 remittance was an estimated tax payment, then, under section 6315, it is considered a payment of income tax for the year of payment.