Said Mahmoud Karara - Page 4




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          deficiency based on reports filed by payers of income.  The                 
          notices of deficiency were issued on January 28, 1998.                      

                                       OPINION                                        
          1.  Whether Respondent Is Barred by the Section 6501(a) Period of           
          Limitations                                                                 
               Petitioner did not file Federal income tax returns for 1993            
          and 1994.  The notices of deficiency for 1993 and 1994 were both            
          issued on January 28, 1998.  Petitioner contends that respondent            
          is barred from making assessments against him because the notices           
          of deficiency were issued more than 3 years from the dates the              
          taxes were due for each of the years at issue.  Petitioner                  
          contends the 1993 taxes were due on January 1, 1994, and the 1994           
          taxes were due on January 1, 1995.  Since the notices of                    
          deficiency were issued more than 3 years from those dates,                  
          petitioner contends that respondent is barred from making                   
          assessments against him.                                                    
               Section 6501(a) provides generally that taxes imposed by the           
          Internal Revenue Code shall be assessed within 3 years after the            
          return is filed, whether or not such return was filed on or after           
          the date prescribed.  Section 6501(c)(3) provides that, in the              
          case of failure to file a return, the tax may be assessed, or a             
          proceeding in Court for the collection of such tax may be begun             
          without assessment at any time.                                             






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