SCHWECHTER v. COMMISSIONER

Docket No. 15583-95.

79 T.C.M. 1438 (2000)

T.C. Memo. 2000-36

Loren H. Schwechter v. Commissioner.

United States Tax Court.

Filed February 4, 2000.


Attorney(s) appearing for the Case

Leonard T. Timpone, for the petitioner. Lauren W. Gore, for the respondent.


MEMORANDUM OPINION

GALE, Judge:

Respondent determined the following deficiencies in petitioner's Federal income tax:

Year   Deficiency

1988     $9,866
1989      1,612
1991        414

We must decide the following:

1. Whether the limitations period for assessing taxes for the years 1988 and 1989 has expired. We hold that it has not.

2. Whether petitioner has made overpayments with respect to 1988 and...

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