116 T.C. No. 5
UNITED STATES TAX COURT
EUGENE M. LANDRY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18558-99L. Filed January 30, 2001.
P’s Federal income tax returns for 1989 through
1997 were filed consistently late. Each return
reflected an overpayment, which P elected to apply to a
subsequent year’s liability. Held: The Court has
jurisdiction because the underlying tax liability
relates to Federal income tax, regardless of whether a
deficiency was determined. Held, further, overpayments
first claimed on returns filed more than 3 years late
are barred, and R may proceed with collection of
balances due as determined in a Notice of Determination
Concerning Collection Action(s).
Eugene M. Landry, pro se.
John D. Faucher, for respondent.
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