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2. Whether the limitation on the time to assess tax for
1994 or 1995 expired before respondent issued the notice of
deficiency. We hold that it did not.
References to petitioner are to Andris Zarins. Section
references are to the Internal Revenue Code in effect during the
years in issue. Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners were married and filed joint returns for 1994
and 1995. They lived in Ostrander, Ohio, during the years in
issue and when they filed their petition.
Petitioners’ parents owned a farm on which they raised
cattle. They also grew trees, of which they sold about 100-200
per year for 3 or 4 years. Petitioner worked on the farm when he
was young, and he attended several farm seminars with his father
over the years. Petitioner took business and economics courses
in college and received an engineering degree before the years in
issue.
Petitioners worked for the State of Ohio during the years in
issue. Petitioner was an engineer and his wife, Zigrida Zarins,
was a computer manager. Petitioner retired in 1997.
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