Bill Max Overton - Page 8

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          section 6654(e) applies.8  Accordingly, we sustain respondent’s             
          determination of section 6654 additions to tax as set forth in              
          the notices of deficiency.                                                  
               In reaching our holding, we have considered all arguments              
          that petitioner raised in his petition.  Arguments not addressed            
          herein are irrelevant or without merit.9                                    
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                              for respondent.                         















               8 The evidence shows that petitioner had Federal income                
          taxes withheld of $158 and $404 for 1996 and 1997, respectively.            
          In the notices of deficiency for these years, respondent                    
          appropriately gave petitioner credit for these amounts of                   
          withholding.                                                                
               9 For example, in his petition, petitioner contends that the           
          limitations period for assessing his 1996 tax has expired.                  
          Assessments must be made within 3 years after a return is filed.            
          Sec. 6501(a).  Because petitioner filed no 1996 return, the                 
          limitations period for assessing his 1996 tax remains open                  
          indefinitely.  See sec. 6501(c)(3).                                         





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