- 3 - Petitioner did not file a timely Federal income tax return for any of the subject years. With respect to his returns for each of the years 1986, 1989, and 1990, the time for filing was extended until August 15 of the year in which the return was due. On May 11, 1995, respondent issued petitioner two notices of deficiency, one for 1986, 1989, and 1990, and the other for 1991 and 1992. Before May 11, 1995, respondent had prepared "returns" for petitioner for each of the subject years under the authority of section 6020(b). After receiving the notices of deficiency, petitioner filed a return for each subject year. He filed his 1986 return on August 8, 1995, his 1989 return on September 15, 1995, his 1990 return on September 18, 1995, his 1991 return on August 28, 1995, and his 1992 return on September 8, 1995. With the exception of a claimed capital loss deduction for 1991, respondent accepted each return as filed. Petitioner amended his returns for 1991 and 1992. Respondent accepted the amended returns as filed. Prior to 1986, petitioner purchased limited and general partnership interests in several oil and gas ventures. These ventures realized operating losses, and petitioner reported his shares of these losses on Schedule C, Profit or (Loss) From Business or Profession, and Schedule E, Supplemental Income. Petitioner also purchased various securities, and he reported on his returns capital losses attributable to worthless securities. Petitioner was entitled to carry over the losses that he wasPage: Previous 1 2 3 4 5 6 7 8 9 Next
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