Robert B. Keenan - Page 4

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          Background                                                                  
               Petitioner resided in Camarillo, California, at the time he            
          filed his petitions.                                                        
               Petitioner was born on August 25, 1923.  He attended college           
          in 1941 and 1942 but did not receive a degree.  Subsequently, he            
          worked as a ship fitter in the shipbuilding industry and then               
          enlisted in the Army Air Corps.  In 1951, he became a pilot for             
          United Airlines.  In 1987, he retired from the airline.  Between            
          1988 and 1993, petitioner flew airplanes for a worldwide delivery           
          firm.                                                                       
               Petitioner failed to file Federal tax returns for 1988, 1990,          
          1991, 1992, 1993, and 1994.                                                 
               For convenience, we have combined our remaining findings of            
          fact and opinion with respect to each issue.                                
          Issue 1.  Statutory Period of Limitations--1989                             
               Petitioner asserts that he timely filed a 1989 tax return and          
          therefore maintains that the period for assessing a deficiency and          
          additions to tax against him for 1989 expired before the date on            
          which respondent mailed the statutory notice of deficiency (May 12,         
          1997) with respect to that year.  Respondent maintains petitioner           
          did not file a 1989 return.                                                 
               In general, an income tax must be assessed within 3 years              
          after the return was filed.  Sec. 6501(a).  If no return is filed,          
          the tax may be assessed, or a proceeding in court for the                   





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