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On October 15, 1996, petitioner filed a petition placing years
1986 through 1994 at issue. On December 13, 1996, respondent filed
a motion to dismiss for lack of jurisdiction and to strike: (1)
Years 1986, 1990, and 1994 on the ground that no deficiencies in
taxes for those years had been determined, and (2) years 1987,
1989, and 1991 on the ground that the petition with respect to
those years was untimely (those years were the subject of a notice
of deficiency dated June 4, 1996). Petitioner conceded that a
notice of deficiency had not been issued for years 1986, 1990, and
1994, and therefore respondent's motion to dismiss those years for
lack of jurisdiction was appropriate. However, petitioner
maintained that dismissal for years 1987, 1989, and 1991 should be
based on the ground that the June 4, 1996, notice of deficiency was
not sent to his last known address. We agreed with petitioner's
position on the last known address issue. See Wilson v.
Commissioner, T.C. Memo. 1997-515. We issued an order on December
3, 1997, dismissing: (1) Years 1986, 1990, and 1994 on the ground
that no notice of deficiency for those years had been issued, and
(2) years 1987, 1989, and 1991 on the ground that the notice of
deficiency for those years was invalid.
Petitioner now seeks refunds for 1988 (in the amount of
$27,268) and 1992 (in the amount of $25,135) Federal income taxes.
The parties stipulated: (1) For 1988, petitioner made estimated
tax payments of $5,000, and a remittance of $8,000 (included with
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