David Dobrich and Naomi Dobrich - Page 7

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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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