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NM D&O 14-32 Personal Income Tax 2014-08-15

Could retirees count a 2012 balance paid in 2013 as a 2013 estimated payment while excluding their January 2014 quarterly estimate?

Short answer: No. Roger and Louise Bumstead's $810 payment made in April 2013 paid their 2012 income-tax balance; its calendar-year payment date did not turn it into a 2013 estimated payment. Conversely, their January 2014 quarterly estimate counted toward tax year 2013 because Section 7-2-12.2 set that installment's due date in the following calendar year. Their four actual 2013 estimates totaled $800, not the $1,410 reported on the return. Against $282 of 2013 tax, the Department correctly issued a $518 refund and the protest was denied.

Apply this to your situation

This page answers the general question as of 2014. Ezel answers yours, under current New Mexico tax law, with citations.

Currency note: this ruling is from 2014
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is a published Decision and Order of the New Mexico Administrative Hearings Office, an independent agency that adjudicates tax protests separately from the Taxation and Revenue Department. It resolves one taxpayer's protest on the specific facts and the law in effect when issued; different facts or later changes in the law can change the result, and another taxpayer should not assume it applies to their situation. A Decision and Order binds the parties to that protest and is not a general ruling or advisory opinion of the Department. This summary is informational only and is not legal or tax advice. Consult a licensed New Mexico tax professional about your specific situation.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Plain-English summary

Roger and Louise Bumstead could not classify payments by the calendar year in which the checks cleared. Their April 2013 payment satisfied their 2012 tax balance, while a January 2014 quarterly estimate applied to tax year 2013.

The retired taxpayers had no wage withholding, so they made quarterly estimated payments. For tax year 2013, they paid four $200 installments—on April 29, June 11, and September 12, 2013, and January 14, 2014—for a total of $800.

They used AARP services at the Bear Canyon Senior Center to prepare their 2013 return. Line 29 reported $1,410 of estimated payments, but that amount combined payments from the wrong periods.

The April 2013 payment belonged to tax year 2012

On April 1, 2013, the Bumsteads filed their 2012 return and electronically paid its $810 balance. Although the transaction happened during calendar year 2013, it paid their tax-year 2012 obligation and was credited accordingly.

The annual filing rule contemplated that payment for one tax year could occur by April 15 of the following calendar year. The $810 therefore was not an estimated payment toward 2013 and did not belong on the 2013 return's estimated-payment line.

The January 2014 estimate belonged to tax year 2013

The Bumsteads made the opposite mistake with their fourth quarterly installment. They left the January 2014 payment off the 2013 return, apparently because it was paid in the next calendar year.

Section 7-2-12.2(D), however, set the quarterly due dates as April 15, June 15, and September 15 of the tax year and January 15 of the following year. The January installment therefore counted toward 2013.

The Department's $518 refund was correct

The four valid 2013 estimates totaled $800. The Bumsteads' 2013 tax liability was $282, leaving a refund of $518.

The Department detected the inaccurate $1,410 entry, adjusted the return to $800, and issued the $518 refund.

Result: protest DENIED. The Return Adjustment Notice and the $518 refund were upheld.

What this means for you

Retirees and others without withholding

Track estimated payments by the tax year designated for each installment, not simply by the year in which money leaves the bank.

Taxpayers paying a prior-year balance

A balance paid with an annual return generally belongs to that return's tax year. Paying it during the next calendar year does not make it a current-year estimate.

Tax return preparers

Reconcile the estimated-payment line against agency records and payment notations. Include the fourth quarterly installment due in January when it was designated for the preceding tax year.

Common questions

Q: Why didn't the April 2013 payment count toward 2013?
A: It accompanied the 2012 return and paid the $810 tax due for 2012.

Q: Why did the January 2014 payment count toward 2013?
A: The estimated-tax statute made the fourth 2013 installment due January 15 of the following calendar year.

Q: How much did the Bumsteads actually prepay for 2013?
A: Four installments of $200, totaling $800.

Q: How was the refund calculated?
A: The decision subtracted the $282 tax liability from $800 of valid estimated payments, producing $518.

Citations and references

Statutes:

  • NMSA 1978, §§ 7-2-3 and 7-2-12 — resident income tax, return, and annual payment deadline
  • NMSA 1978, § 7-2-12.2 — quarterly estimated income-tax payments and due dates

Source

Original ruling text

BEFORE THE HEARING OFFICER
OF THE TAXATION AND REVENUE DEPARTMENT
OF THE STATE OF NEW MEXICO

IN THE MATTER OF THE PROTEST OF
ROGER & R. LOUISE BUMSTEAD No. 14-32
TO RETURN ADJUSTMENT NOTICE ISSUED UNDER LETTER
ID NO. L2057274320

DECISION AND ORDER

A protest hearing occurred on the above captioned matter on August 7, 2014, before

Brian VanDenzen, Esq., Hearing Officer, in Santa Fe. Mr. Roger Bumstead appeared pro se for

himself and Louise Bumstead (“Taxpayers”). Staff Attorney Elena Morgan appeared

representing the State of New Mexico, Taxation and Revenue Department (“Department”).

Protest Auditor Sonya Varela appeared as a witness for the Department. Taxpayer Exhibits 1-9

and Department Exhibit A-C were admitted into the record, as described more thoroughly in the

Administrative Protest Hearing Exhibit Log. Based on the evidence and arguments presented, IT

IS DECIDED AND ORDERED AS FOLLOWS:

FINDINGS OF FACT

  1. On April 4, 2014, under letter id. number L2057274320, the Department sent

Taxpayers a Return Adjustment Notice.

  1. On May 20, 2014, Taxpayers protested the Department’s April 4, 2014 Return

Adjustment Notice.

  1. On July 18, 2014, the Department requested a hearing in this matter with the

Hearings Bureau.

  1. On July 18, 2014, the Hearings Bureau sent Notice of Administrative Hearing,

scheduling this matter for the hearing on August 7, 2014.

  1. For the personal income tax year ending on December 31, 2012, Taxpayers owed

$810.00 in New Mexico personal income tax. [Department Ex. A].

  1. On April 1, 2013, Taxpayers submitted their 2012 personal income tax return and

electronic debit payment of $810.00 for their outstanding 2012 personal income tax obligation.

[Department Ex. A and Taxpayer Ex. #3].

  1. Even though the payment was made on April 1, 2013, since the payment was to

satisfy the amount of 2012 personal income tax due under that return, the Department credited

the $810.00 payment to Taxpayers’ 2012 personal income tax.

  1. For personal income tax year 2013, since Taxpayers are retired without any wage

withholdings, Taxpayers made four estimated payments of income tax totaling $800.00.

[Department Ex. B].

a. On April 29, 2013, Taxpayer made a $200.00 estimated payment of tax,

indicating on the check comments that it was for the “2013 April Quarter.”

[Department Ex. B-4 and Taxpayer Ex. #6 & #9].

b. On June 11, 2013, Taxpayer made a $200.00 estimated payment of tax indicating

on the check comments that it was for the “N.M. 2013 ¼ Inc. Tax Fund.”

[Department Ex. B-5 and Taxpayer Ex. #7 & #9].

c. On September 12, 2013, Taxpayer made a $200.00 estimated payment of tax,

indicating on the check comments Taxpayers social security numbers.

[Department Ex. B-6 and Taxpayer Ex. #8 & #9].

In the Matter of the Protest of Roger & R. Louise Bumstead, page 2 of 6
d. On January 14, 2014, Taxpayer made a $200.00 estimated payment of tax,

indicating on the check comments that it was for the “2013 Est. Tax Payment.”

[Department Ex. C].

  1. Taxpayers used the services of AARP at Bear Canyon Senior Center to assist in

preparation of the 2013 personal income tax returns.

  1. Taxpayers’ total 2013 personal income tax liability was $282.00. [Department Ex.

B-2].

  1. While Taxpayers in fact only made $800.00 in 2013 estimated personal income

tax payments, Taxpayers listed $1410.00 in estimated personal income tax payments on line 29

of their 2013 personal income tax return. [Department Ex. B-2].

  1. In error, Taxpayers’s return included their $810.00 payment of 2012 personal

income tax as a 2013 estimated income tax payment. Although the $810.00 payment occurred

during calendar year 2013, it was the payment for the outstanding 2012 personal income tax

liability, not an estimated payment towards their 2013 personal income taxes.

  1. In error, Taxpayers only included three of their four quarterly estimated income

tax payments totaling $600.00 as estimated income tax payments on their 2013 personal income

tax return when in fact Taxpayers made four quarterly payments towards 2013 income tax

totaling $800.00.

  1. The correct amount of 2013 estimated income tax payments that should have been

listed on line 29 was $800.00. With that correct amount of 2013 estimated income tax payments

listed on line 29, Taxpayers were due a refund of $518.00.

  1. Upon receipt of Taxpayers’ 2013 personal income tax returns, the Department

reviewed the return and its record and found that Taxpayers had only made $800.00 in estimated

In the Matter of the Protest of Roger & R. Louise Bumstead, page 3 of 6
personal income tax returns in 2013 rather than the reported $1410.00. The Department then

issued the Return Adjustment Notice identified under finding of fact #1.

  1. Taxpayers in fact received a refund in the correct amount of $518.00 in this

matter. [Department Ex. B-3].

DISCUSSION

Taxpayers believed that because their $810.00 payment of their 2012 personal income tax

liability occurred during calendar year 2013, that amount should be included on line 29 of their

2013 personal income tax return as part of their 2013 estimated personal income tax returns.

Further, Taxpayers did not include the quarterly $200.00 2013 estimated personal income tax

payment that they made in January of 2014 on line 29, apparently because they believed since it

was made in a different calendar year, it did not count towards their 2013 personal income taxes.

When the Department adjusted Taxpayers’ 2013 personal income tax return to reflect the

accurate $800.00 total in 2013 estimated tax payments, reducing their refund to $518.00,

Taxpayers protested that they were still entitled to a larger refund based on the $1410.00 amount

they reported as 2013 estimated tax reports.

Payment of New Mexico personal income tax is governed by NMSA 1978, §§ 7-2-1 to

  1. Unless otherwise exempted by law, a tax is imposed “upon the net income of every” New

Mexico resident. NMSA 1978, § 7-2-3 (1981). NMSA 1978, Section 7-2-12 (2003) requires any

resident or any person deriving income from New Mexico to file a state income tax return. Under

Section 7-2-12, the required tax return and any amount of tax due under the return are due “on or

before the fifteenth day of the fourth month following the end of the taxable year”, which is

April 15th of the next calendar year. The statute thus contemplates that a tax payment may not

occur until the calendar year following the end of the taxable year at issue.

In the Matter of the Protest of Roger & R. Louise Bumstead, page 4 of 6
Like this protest, where a taxpayer does not have any withholdings, that taxpayer is

required to make quarterly estimated payments of income tax under NMSA 1978, Section 7-2-

12.2 (2011). Under Section 7-2-12.2 (D), those quarterly estimated payments are due on “April

15, June 15, and September 15 of the taxable year and January 15 of the following taxable year.”

(emphasis added). In other words, again the statute contemplates that one estimated quarterly

payment will not be made during the taxable year but in the calendar year following the taxable

year in question.

Taxpayers’ April 1, 2013 $810.00 payment of tax was payment of Taxpayers’ 2012

personal income tax, a timely payment of 2012 personal income tax under Section 7-2-12. That

payment was credited towards Taxpayers’ 2012 personal income tax year obligations, not

towards any potential 2013 personal income tax year liabilities. Just because the 2012 personal

income tax year payment of $810.00 occurred during calendar year 2013, Taxpayers were not

entitled to include that $810.00 as an estimated 2013 personal income tax payment. The April 1,

2013 $810.00 payment was not an estimated payment towards Taxpayers’ 2013 personal income

tax year liabilities, but a payment of Taxpayers’ tax year 2012 liabilities, and thus should not

have been included on line 29 of Taxpayers’ 2013 personal income tax return.

For tax year 2013, Taxpayers made four estimated payments of tax totaling $800.00.

While the January 2014 estimated payment occurred in calendar year 2014 rather than 2013, it

still applies as an estimated payment for tax year 2013 under the deadlines established by Section

7-2-12.2 (D). Consequently, Taxpayers should have included that additional $200.00 estimated

tax payment from January 2014 on line 29 of their 2013 personal income tax return.

The Department properly detected the error on estimated tax payments reported on line

29 of Taxpayers’ 2013 personal income tax returns. The Department correctly adjusted

In the Matter of the Protest of Roger & R. Louise Bumstead, page 5 of 6
Taxpayers’ 2013 personal income tax return with the correct amount of estimated tax payments

that Taxpayers in fact made towards the 2013 personal income tax year. The Department then

issued Taxpayers the correct refund amount of $518.00. Taxpayers’ protest to the Department’s

Return Adjustment Notice is denied.

CONCLUSIONS OF LAW

A. Taxpayer filed a timely, written protest to the Return Adjustment Notice. The

hearing timely was set within 90-days of protest. Jurisdiction lies over the parties and the subject

matter of this protest.

B. Under Section 7-2-12, Taxpayers’ April 1, 2013 $810.00 payment included with

their 2012 personal income tax return was a timely payment of their year 2012 personal income

tax liability before the April 15, 2013 due date, not an estimated payment of year 2013 personal

income taxes.

C. Taxpayers timely made four estimated income tax payments for tax year 2013

totaling $800.00, including the estimated payment made in January 2014.

D. The Department properly adjusted Taxpayers return to reflect the accurate amount

of tax year 2013 estimated payments actually made and provided Taxpayers with the correct

refund of $518.00.

For the foregoing reasons, Taxpayer’ protest IS DENIED.

DATED: August 15, 2014.

Brian VanDenzen, Esq.,
Chief Hearing Officer
Taxation & Revenue Department
Post Office Box 630
Santa Fe, NM 87504-0630

In the Matter of the Protest of Roger & R. Louise Bumstead, page 6 of 6

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