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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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