Robert C. Austin - Page 2

                                  Additions to Tax                                    
                                  Sec.       Sec.      Sec.           Sec.            
          Year       Deficiency    6651       6653(a)     6654         6661           
          1984       $8,723      $2,174       1$444         ---      $2,181           
          1985        7,871       1,929        1406         ---       1,968           
          1986       10,899       2,678        1548         ---       2,725           
          1987 20,519 5,130 --- --- ---                                               
          1988       52,421       8,158         ---       3,353         ---           
          1990       11,351       2,838         ---         747         ---           
          1991       18,310       4,578         ---       1,053         ---           
          1 Plus 50 percent of the interest due on the deficiency.                    
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the taxable years before            
          the Court, and all Rule references are to the Tax Court Rules of            
          Practice and Procedure.                                                     
               The issue to be decided is whether petitioner's remittance             
          in the form of a check in the amount of $19,789.96, sent to the             
          Internal Revenue Service with petitioner's 1988 Form 4868,                  
          Application for Automatic Extension of Time to File U.S.                    
          Individual Income Tax Return, on or about April 15, 1989, was a             
          payment of tax or a deposit in the nature of a cash bond.                   
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits attached thereto are              
          incorporated herein by this reference.                                      
               Petitioner resided in Greeneville, Tennessee, at the time he           
          filed his petition in this case.  In 1984, petitioner was 38                
          years of age.  Up to that time he had led a very sheltered and              
          privileged life.  He had no idea what his assets were and no idea           






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