-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.
Background
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
degree.
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