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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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