Lee R. Stevens - Page 12

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          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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