Keith Lee Wilson - Page 3

          petitioner's request for an extension of time to file his 1988              
          return), petitioner's tax liability is $5,859, and no additions to          
          tax are due; (2) for 1992, petitioner made payments (through                
          withholdings) totaling $39,368.97, petitioner's tax liability is            
          $41,300, and no additions to tax are due; and (3) for 1993, there           
          is no deficiency, additions to tax, or overpayment.                         
               The unresolved issues are:  (1) The amount of overpayment for          
          1988; (2) whether there is a deficiency or overpayment for 1992;            
          and (3) whether the statutorily imposed time limitations of                 
          sections 6511 and 6512 preclude petitioner from obtaining refunds           
          for years 1988 and 1992 (if an overpayment exists for 1992).                
               All section references are to the Internal Revenue Code in             
          effect for the years under consideration.  All Rule references are          
          to the Tax Court Rules of Practice and Procedure.                           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are found                   
          accordingly.  The stipulation of facts and the exhibits submitted           
          therewith are incorporated herein by this reference.                        
               At the time petitioner filed his petition, he resided in               
          Pacific Palisades, California.  In 1974, petitioner received a              
          juris doctorate from UCLA.  He subsequently took graduate tax               
          courses at New York University School of Law but did not receive a          

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