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petitioners were required to include the income from real
property sales for 1989.
Accordingly, petitioners have not shown that the question of
an overpayment for 1990 was raised and/or in issue prior to the
submission of the Rule 155 computation. Petitioners' argument
that the limitations period is still open within which a refund
for 1990 could be claimed falls short of the statutory
requirements in several obvious respects. Petitioners have not
shown that they have met the requirements of sections 6501, 6511,
or 6512. We therefore hold that petitioners are not entitled to
an overpayment for 1990.
To reflect the foregoing,
Decisions will be entered in
accord with this opinion in docket
No. 3832-95 and for petitioners in
docket No. 7382-96.
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Last modified: May 25, 2011