-13-
1992 tax liability is $41,300. Thus, petitioner is liable for the
difference, or $1,931.03.9
In reaching our holding herein, we have considered all of
petitioner's arguments. We conclude each of them is without merit.
To reflect the foregoing and the stipulations of the parties,
A decision will be entered
that (1) for 1988 and 1993 there are
no deficiencies, additions to tax, or
overpayments, and (2) for 1992 there
is a deficiency in tax in the amount
of $1,931.03, but no additions to
tax.
9 Assuming arguendo an overpayment for 1992 exists (as
contended by petitioner), such overpayment is barred by the
statute of limitations pursuant to secs. 6511(a), (b)(2), and
6512(b)(3)(B) (as discussed above with regard to 1988).
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011