Ronald A. Mason - Page 5




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          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, and                






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