Elgin E. Flagg - Page 3

                                        - 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 was                




Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011