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Assuming that there were overpayments for 1993, 1994, and
1995, this result may seem harsh. But, the result flows directly
from petitioner’s failure to file timely tax returns for those
years.4
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
Decision will be entered for
respondent with respect to the
deficiency and additions to tax
under sections 6651(a)(1) and
6654(a) and for petitioner with
respect to the addition to tax
under section 6651(a)(2).
4 While petitioner filed a return in 1998 for 1993, the
refund claimed was time barred.
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Last modified: May 25, 2011