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The Court rejects petitioner's contention that respondent is
barred from making assessments against him for the 2 years in
question. Since no returns were filed, section 6501(c)(3)
provides expressly that assessment may be made at any time.
Moreover, petitioner is in error in claiming that the taxes were
due on January 1, 1994, and on January 1, 1995. Calendar year
taxpayers are, under section 6072(a), required to file their
income tax returns and pay the taxes thereon on or before April
15th following the close of the taxable year. The Court,
therefore, rejects petitioner's claim that respondent is barred
by the period of limitations under section 6501(a).
2. Gain on Redemption of Stock
Under section 1001(a), gain from the sale or other
disposition of property is the excess of the amount realized over
the adjusted basis of the property. In this case, the parties
agree that petitioner realized $5,277 and $1,287 in 1993 and
1994, respectively, on the redemption of Citizen's Federal Stock
owned by petitioner. At issue is the adjusted basis of the
redeemed stock in the hands of petitioner.
Generally, under section 1012, the basis of property is its
cost. The cost is the amount paid for such property in cash or
other property. See sec. 1.1012-1(a), Income Tax Regs. Thus,
petitioner must demonstrate the economic outlay necessary for
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