Gary R. Greulich - Page 7

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          Commissioner, T.C. Memo. 2002-308; Lee v. Commissioner, T.C.                
          Memo. 2002-233.  Petitioner’s claim to the balance in the “excess           
          collections” account was, therefore, time barred.                           
               The result may appear somewhat harsh, but it must be pointed           
          out that the result flows from petitioner’s actions in not timely           
          filing his tax returns.  All of this could have been avoided if             
          petitioner had followed the statutory provisions for filing                 
          returns.  Those provisions are not obscure. We sustain                      
          respondent’s determination.                                                 
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              
                                             Decision will be entered                 
                                        for respondent.                               























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