Said Mahmoud Karara - Page 2




                                        - 2 -                                         

               Respondent determined deficiencies in petitioner's Federal             
          income taxes and additions to tax as follows:                               

                 Additions to Tax                                                     
          Year      Deficiency      Sec. 6651(a)      Sec. 6654(a)                    
          1993        $2,696           $674.00           $112.93                      
          1994         1,489            372.25             -0-                        

               The issues for decision are:  (1) Whether the period of                
          limitations under section 6501(a) bars respondent from making               
          assessments against petitioner for the years 1993 and 1994;                 
          (2) whether, for 1993 and 1994, petitioner realized a gain,                 
          pursuant to section 1001(a), on the redemption of certain shares            
          of Citizens Federal Bank Non-Cumulative Preferred Stock (Citizens           
          Federal Stock);  (3) whether, for 1993 and 1994, petitioner was             
          engaged in a trade or business activity under section 162(a);               
          (4) whether petitioner is liable for the addition to tax under              
          section 6651(a) for failure to file returns for 1993 and 1994;              
          and (5) whether, for 1993, petitioner is liable for the addition            
          to tax under section 6654(a) for failure to make estimated tax              
          payments.2                                                                  


               2    Issue number 1 was presented by petitioner at trial by            
          way of a motion to dismiss for lack of jurisdiction on the ground           
          that respondent was barred by the period of limitations under               
          sec. 6501(a).  Respondent filed an objection, affirmatively                 
          alleging that the notices of deficiency were not barred because             
          petitioner did not file Federal income tax returns for the 2                
          years at issue.  The Court denied petitioner's motion to dismiss            
                                                             (continued...)           




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011