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made when they filed the Form 4868, they reported that they had a
balance due of $13,776.33, which they paid with the return.
4. Audit of Petitioners’ 1991 and 1992 Returns
On September 26, 1994, respondent's auditor wrote a letter
to petitioners enclosing a report recommending additions to tax
under section 6651(a)(1) in the amount of $3,375 for 1991 and
$2,404 for 1992. The letter said the 1991 and 1992 returns had
the same disputed Form 4868 issue that was present on
petitioners’ 1990 return, and that respondent’s auditor wanted to
keep the 3 years together.
Respondent issued a notice of deficiency for 1991 and 1992
on December 19, 1994. Petitioners filed the petition for tax
years 1991 and 1992 (docket No. 2613-95) on February 16, 1995.
5. Summary
The following compares the amount of tax liability
petitioners estimated on Forms 4868 for the years in issue with
the amounts they reported on Forms 1040 or have otherwise
conceded for those years:
Tax Liability
Tax Estimated Tax Reported Conceded by
Year on Form 4868 on Form 1040 Petitioners
1990 $6,000 $18,773.21 $31,856
1991 9,800 24,865.52 25,118
1992 22,000 35,776.33 35,776
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