- 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 the
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011