Grant K. Hagestad - Page 4

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          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.                                                          










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