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1991, 1992, and 1993 taxable years. The issues we must decide
are whether petitioner’s claim that notice and demand for payment
was not sent to his last known address is barred by the doctrine
of res judicata; whether the period of limitations on assessment
of petitioner’s 1990 and 1991 income taxes expired; whether
petitioner engaged in tournament sport fishing with the intent to
make a profit as defined by section 183; and whether the lien may
remain in place.
Background
The parties failed to submit a stipulation of facts but did
stipulate the admission of certain exhibits. At the time of
filing the petition, petitioner resided in Raleigh, North
Carolina.
During the years 1990 through 1993, Eastman Kodak Co.
(Kodak) employed petitioner full time in Rochester, New York.
As a full-time employee, petitioner worked at least 40 hours per
week at Kodak. At the same time, petitioner engaged in the
private practice of architecture between October and May of each
year.
On Schedules C, Profit or Loss From Business, of his 1990
through 1993 Federal income tax returns, petitioner indicated
that he was engaged in the business of tournament sport fishing
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