- 4 - Background Petitioner resided in Camarillo, California, at the time he filed his petitions. Petitioner was born on August 25, 1923. He attended college in 1941 and 1942 but did not receive a degree. Subsequently, he worked as a ship fitter in the shipbuilding industry and then enlisted in the Army Air Corps. In 1951, he became a pilot for United Airlines. In 1987, he retired from the airline. Between 1988 and 1993, petitioner flew airplanes for a worldwide delivery firm. Petitioner failed to file Federal tax returns for 1988, 1990, 1991, 1992, 1993, and 1994. For convenience, we have combined our remaining findings of fact and opinion with respect to each issue. Issue 1. Statutory Period of Limitations--1989 Petitioner asserts that he timely filed a 1989 tax return and therefore maintains that the period for assessing a deficiency and additions to tax against him for 1989 expired before the date on which respondent mailed the statutory notice of deficiency (May 12, 1997) with respect to that year. Respondent maintains petitioner did not file a 1989 return. In general, an income tax must be assessed within 3 years after the return was filed. Sec. 6501(a). If no return is filed, the tax may be assessed, or a proceeding in court for thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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