- 17 - stipulated that, other than the nontaxable sources agreed to above and the contested cash gift, there are no other possible nontaxable sources for the amounts omitted from petitioner's returns for 1989 and 1990. OPINION We must decide whether certain of petitioner's bank deposits and cash expenditures constitute unreported gross income in excess of 25 percent of the amount of gross income stated in petitioner's return, so that assessment and collection of income tax thereon is not barred by reason of the 6-year period of limitations provided by section 6501(e)(1)(A). If assessment and collection is not so barred, we must also decide whether the unreported bank deposits and cash expenditures made by petitioner constitute self-employment income subject to tax pursuant to section 1401 for 1989 and 1990. We must also decide whether petitioner is liable for accuracy-related penalties for negligence pursuant to section 6662(a) for those taxable years. I. Does the Period of Limitations Bar Respondent's Assessment of Deficiencies for 1989 and 1990? Generally, no deficiency in income tax may be assessed or collected more than 3 years after the return is filed. Sec. 6501(a). In the instant case, there is no dispute that the deficiency notice was mailed to petitioner after the expiration of the 3-year period of limitations, but within the 6-year period of limitations.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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