Guillermo Baez Espinosa v. Commissioner

107 T.C. No. 9

UNITED STATES TAX COURT GUILLERMO BAEZ ESPINOSA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8900-94. Filed September 24, 1996. P, a nonresident alien individual, failed to file Federal income tax returns for the years 1987 through 1991. R repeatedly notified P of his failure to file. R prepared substitute returns for P and notified P that pursuant to sec. 874(a), I.R.C., no deductions were allowable. P subsequently submitted returns claiming the benefit of deductions. R then issued a notice of deficiency. Held: P is not entitled to the benefit of…