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Year Erroneous Refund1
1988 $1,900
1989 4,600
1990 4,900
1991 5,400
1992 6,500
23,300
1Rounded to the nearest $100.
Respondent never examined any of petitioner’s income tax
returns for 1988 through 1992.5 However, in 1996, respondent
commenced examinations of petitioner’s income tax returns for
1993 through 1995.
B. The Taxable Year 1993
1. Petitioner’s 1993 Tax Return and Notice of Deficiency
Petitioner timely filed a Federal income tax return for
1993. See sec. 6072(a).
In or about July 1996, petitioner was notified in writing of
the examination of her 1993 income tax return through the receipt
of an examination report dated July 19, 1996. The examination
report proposed, inter alia, to disallow the deduction petitioner
claimed for gifts to family members of $16,539.
On or about August 18, 1996, petitioner mailed a letter to
5 Petitioner admits that she was “well rewarded” through
the receipt of refunds for the taxable years 1988 through 1992
for which there was no basis in law and the recovery of which by
respondent is barred by the statute of limitations on assessment.
See sec. 6501.
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