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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 was
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