- 4 -
wherein we decided that such income was properly reported by
petitioner in 1987. The amount of tax petitioner paid for 1987
was never different from the amount he reported on his 1987
return.
During June 1993, petitioner filed claims for refund for the
1989, 1990, and 1991 taxable years, in which petitioner claimed
carryovers of the 1986, 1987, and 1988 suspended CLD's, pursuant
to section 465(a)(2). The amount of the deduction which was
carried forward from 1987 to 1991 was $171,318. The claims for
1990 and 1991 were handled by Revenue Agent Phillip Valenzuela,
who was thoroughly familiar with the 1991 notice of deficiency
and the 1992 stipulation. The claim for 1989 was allowed by
respondent on or about May 31, 1993. The claims for 1990 and
1991 were allowed by respondent on April 17, 1995 (the 1995
refund).
For the purposes of applying section 6501(e)(1), the amount
of gross income reported by petitioner for taxable year 1987 was
$2,092,344. Neither petitioner nor respondent executed any
waivers or extensions pursuant to section 6501(c)(4) for
extending the period of time for assessing the tax liability for
any year at issue.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011