- 6 - 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 werePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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