-2- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011