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maximum of 25 percent. While petitioners delivered signed 1990 and
1991 joint returns to respondent's counsel on November 14, 1994,
they filed nothing for those years prior to that time. Since
extensions of time within which to file were neither requested nor
granted for 1990 and 1991, the returns for those years were due on
April 15, 1991, and April 15, 1992, respectively. Petitioners are
therefore liable for the 25percent delinquency additions to tax for
1990 and 1991 pursuant to section 6651(a)(1).
Petitioners made a 1990 estimated tax payment of $6,659, and
are entitled to a $183 withholding tax credit for 1990, and made no
estimated tax payments for 1991. Petitioners are liable for the
addition to tax under section 6654 for failing to make sufficient
estimated tax payments for those years. The correct amounts of
underpayment and additions to tax under section 6654 will be
determined under Rule 155.
To reflect the foregoing,
Decisions will be
entered under Rule 155.
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Last modified: May 25, 2011