-7-
information documents. Petitioner's tax liability for 1992 is
$41,300.
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.
OPINION
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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