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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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Last modified: May 25, 2011