- 6 - his overpayment is the direct result of his failure to file a return and pursuant to the application of the above-described provisions of the Internal Revenue Code. We therefore hold that the statutorily imposed time limitations of sections 6511 and 6512 bar us from determining that petitioner is entitled to a refund with respect to his 1999 tax. See Commissioner v. Lundy, supra; Badger v. Commissioner, T.C. Memo. 1996-314; Stevens v. Commissioner, supra. Reviewed and adopted as the report of the Small Tax Case Division. To reflect the foregoing, Decision will be entered for respondent as to the deficiency in the amount of $9,344 and for respondent as to the overpayment.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011