- 4 - taxable years 1987 through 1991, his Federal income tax returns were due on June 15 of the year following the close of the taxable year. Sec. 6072(c). As of November 13, 1992, petitioner had not filed any Federal income tax returns for the years in issue. On that date, respondent mailed a letter to petitioner asking him if he had filed returns and, if he had not, instructing him to file returns or otherwise respond. That letter also stated that, if petitioner did not respond by December 1, 1992, respondent would file substitute returns for him. Petitioner did not respond, and on January 12, 1993, respondent again wrote petitioner with the same request, adding that, if there was no response within 20 days, "your tax liability [will be determined] based on the information we have." Again petitioner did not respond. On February 3, 1993, respondent notified petitioner that respondent had filed substitute returns for the taxable years 1987 through 1991. On March 23, 1993, respondent informed petitioner that the substituted returns were computed without the benefit of any deductions. On October 7, 1993, petitioner submitted Federal income tax returns for all the years in issue. The returns reflected the net losses from the rental properties described above. Each return contained an election pursuant to section 871(d), to treatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011