-4- computations are based upon the allowance of the standard deduction and one personal exemption, as in effect for each year. Petitioner timely filed a petition in this Court on October 1, 1993; he filed an amended petition on December 6, 1993. The amended petition not only contests the 1989 and 1990 deficiencies and additions to tax, but contains a claim for tax refunds of $906 and $571 for 1989 and 1990, respectively. Petitioner stated in the amended petition that he is entitled to his itemized deductions. On February 4, 1994, respondent filed an answer to the amended petition, generally denying petitioner’s allegations. On or about February 25, 1994, petitioner mailed respondent copies of his 1989 and 1990 Federal income tax returns, which petitioner alleges were timely filed on April 15, 1990, and April 15, 1991, respectively. On March 15, 1994, respondent received these documents. The returns reflect tax overpayments of $2,0962 and $2,135 for 1989 and 1990, respectively, and claimed corresponding refunds. Respondent accepted these returns as filed on March 15, 1994. As stated, respondent acknowledges that petitioner owes no tax deficiencies or additions to tax for 1989 or 1990, but contends that petitioner’s refund claims for such years are time-barred. 1 The amended petition does not specify how these figures were determined. 2 Petitioner claimed a $2,068 overpayment on the copy of his 1989 Federal income tax return. After respondent discovered a mathematical error, respondent corrected the 1989 return to reflect a $2,096 overpayment.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011