Eugene M. Landry - Page 1

                                   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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