- 5 - Apple computer. Nonetheless, petitioner timely filed his return for 1992. Sometime shortly thereafter, petitioner began to use a new tax software program, which was much more complicated than the tax software program he had previously used. Petitioner did not file his returns for 1993 and 1994 until sometime in February or early March 2000. During 1995, petitioner made estimated tax payments for his taxable year 1995 totaling $125,000. On April 15, 1996, peti- tioner requested respondent to grant him an automatic extension of time to file his 1995 return on or before August 15, 1996. That request was granted by respondent. Petitioner did not timely file his return for 1995. That was because he was too busy with his activities relating to the operations of two Richard’s restaurants, an art gallery, and stock investments. On November 27, 1996, respondent prepared a substitute for return for petitioner for 1995. On March 13, 2000, petitioner filed his 1995 return with respondent. In that return, petitioner claimed an overpayment in the amount of $61,151, which he elected to apply as a credit to his taxable year 1996. Petitioner is barred by the statute of limitations from applying that overpayment as a credit to his tax liability for taxable year 1996. Petitioner did not timely file his return for 1996. That was because he was too busy with his activities relating to the operations of two Richard’s restaurants, an art gallery, andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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