T.C. Memo. 1998-277
UNITED STATES TAX COURT
JOHANNES M. SCHALEKAMP, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17980-96. Filed July 29, 1998.
P filed his 1989 Form 1040NR on May 29, 1990.
The notice of deficiency was issued on May 22, 1996.
Held: the deficiencies determined are barred by the
expiration of the period of limitations. Sec. 6501(a),
I.R.C.
William M. Sharp, Sr., William T. Harrison III, and Vernon
Jean Owens, for petitioner.
Howard P. Levine for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: By notice of deficiency dated May 22, 1996,
respondent determined a $4,834,273 deficiency in petitioner's
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