-12-
1989 or 1990 overpayments. We therefore hold that the statutorily
imposed time limitations of sections 6511 and 6512 bar us from
determining that petitioner is entitled to refunds with respect to
his 1989 and 1990 income taxes. See Commissioner v. Lundy, supra.
To reflect the foregoing and respondent’s concessions,
Decision will be entered for
petitioner as to the deficiencies
and additions to tax and for
respondent as to the overpayments.
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Last modified: May 25, 2011