Keith Lee Wilson - Page 7

          information documents.  Petitioner's tax liability for 1992 is              
               For 1992, petitioner paid $39,368.97 in withheld income taxes.         
          Notice of Deficiency                                                        
               In the notice of deficiency mailed on July 8, 1996, respondent         
          determined that petitioner failed to file returns for 1988, 1992,           
          and 1993 and is liable for deficiencies and additions to tax for            
          those years in amounts stated earlier.  The notice of deficiency is         
          based upon the substitute returns, and the deficiency computations          
          are based upon the allowance of the standard deduction and one              
          personal exemption.                                                         
               As a consequence of the parties' stipulations with respect to          
          1993, the only disputed years are 1988 and 1992.  Petitioner                
          contends that he is entitled to refunds for both of these years.            
          Respondent agrees that petitioner would be entitled to a refund for         
          1988 but for the expiration of the period of limitations.  However,         
          respondent disagrees with the amount of overpayment petitioner              
          claims.  For 1992, respondent maintains that petitioner is not              
          entitled to a refund, but rather, owes taxes.                               
               The task before us has been rendered more difficult because of         
          the existence of computational errors and other mistakes in                 
          respondent's records regarding petitioner's 1986-93 tax years, and          
          the incoherent manner in which petitioner presented the facts.              

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