- 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
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