Mark J. and Deborah A. Hanna - Page 6

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               1988                                                                   
               Mr. Hanna testified that petitioners’ 1988 return was mailed           
          on or about October 15, 1989, and that it was not until he                  
          requested a copy of petitioners’ 1988 return from the IRS that he           
          discovered that the 1988 return had not been filed.  This                   
          explanation is implausible.  The 1988 return indicated that                 
          $21,513.99 was owed by petitioners.  Petitioners presumably would           
          have noticed if a check in this amount had been sent with the               
          return and had not cleared their account.  If no check was sent,            
          they would have expected to receive a notice to pay the balance             
          shown.                                                                      
               Mr. Hanna claims to have requested another extension to file           
          petitioners’ 1988 return after discovering that the 1988 return             
          had not been filed with the IRS.  He testified that this                    
          extension was granted, extending the due date for petitioners’              
          1988 return until October 15, 1990.  A document was introduced at           
          trial that purported to be a copy of the approved extension                 
          request that extended the due date of petitioners’ 1988 return              
          until October 15, 1990.  IRS records regarding the 1988 tax year            
          to which petitioners stipulated do not indicate that the IRS ever           
          received this request or that such a request was approved.  In              
          this case, the maximum extension authorized by law is 6 months.             
          Sec. 6081(a).                                                               
               While we question the validity of the purported 1990                   
          extension, we need not reach that issue.  Petitioners were                  




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