- 7 - 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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011