- 11 - Petitioner and Evalyn filed a joint tax return for 1992 and a joint tax return for 1996. Petitioner did not file Maryland State tax returns for the years in issue by October 15 of the following year. Petitioner and Evalyn filed joint tax returns for 1993, 1994, and 1995 on or before March 11, 1997. OPINION From the parties’ stipulations, it appears that the parties agree that petitioner’s and Evalyn’s total tax liability for the 3 years in issue is about $104,000 to $105,000 and that petitioner’s payments toward these 3 years’ liabilities total about $144,000. Respondent contends that credit or refund of petitioner’s and Evalyn’s 1993 and 1994 overpayments is time-barred, that petitioner has a 1995 underpayment of about $9,000, and that petitioner also is liable for 1995 additions to tax under sections 6651(a) and 6654. These contentions are based on respondent’s position that petitioner did not file tax returns for these 3 years until December 4, 1998. Petitioner maintains that credit or refund of his 1993 and 1994 overpayments is not time-barred and that he is not liable for any 1995 additions to tax, and that these results depend upon whenPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011