Lee R. Stevens - Page 2

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               Respondent’s determinations were reflected in two notices of           
          deficiency, one for each of the years involved.  Respondent now             
          concedes the deficiencies and all additions to tax for both years           
          involved.                                                                   
               Petitioner seeks refunds for claimed overpayments of his 1989          
          and 1990 Federal income taxes; respondent contends the refunds              
          sought are time-barred.  Accordingly, the issue for decision is             
          whether petitioner is entitled to refunds for claimed overpayments          
          of his 1989 and 1990 Federal income taxes, or whether the                   
          statutorily imposed time limitations of sections 6511 and 6512              
          preclude him from obtaining any portion of his overpayments.                
          Resolution of this issue depends on whether petitioner  filed his           
          1989 and 1990 Federal income tax returns as of the date the notices         
          of deficiency were mailed.                                                  
               All section references are to the Internal Revenue Code in             
          effect for the years under consideration.  All Rule references are          
          to the Tax Court Rules of Practice and Procedure.                           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are found                   
          accordingly.  The stipulation of facts and the attached exhibits            
          are incorporated herein by this reference.                                  
               At the time he filed his petition, Lee R. Stevens (petitioner)         
          resided in Falls Church, Virginia. Petitioner has a bachelor of             
          arts degree in political science, and two masters of arts degrees,          
          one in public administration and the other in marine affairs.               




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