John Wesley Winters, Jr. - Page 4

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          offered no explanation of why any losses that were incurred in              
          1994, 1995, and 1996 would not have been taken into account when            
          he belatedly filed, in 1997, his return for 1993.                           
               Petitioner has failed to show that the assessed liability              
          for 1993 is erroneous in any respect.  Although he claims                   
          inability to pay the liability, he has neither offered any                  
          collection alternatives nor complied with requirements for an               
          offer in compromise.  See sec. 301.7122-1, Proced. & Admin. Regs.           
               On the record in this case, the notice of determination that           
          was sent to petitioner must be sustained.                                   

                                                  Decision will be entered            
                                             for respondent.                          

























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