Layne E. Preslar and Sue F. Preslar - Page 10

                                       - 10 -                                         
          Memo. 1981-153, affd. 685 F.2d 436 (8th Cir. 1982); sec. 1.6081-            
          4(a)(3), Income Tax Regs.                                                   
               Petitioners contend:  (1) That because they filed a Form               
          4868, their 1989 tax return was not due until August 15, 1990;              
          and (2) that the complicated nature of their 1989 tax return                
          qualifies as reasonable cause for failure to timely file.                   
               Because respondent did not receive petitioners' Form 4868              
          until August 20, 1990, the automatic extension that petitioners             
          sought was not triggered, and petitioners' 1989 tax return was              
          due to be filed on April 15, 1990.                                          
               Further, petitioners have not established reasonable cause             
          for failure to timely file their 1989 Federal income tax return.            
          The mere fact that preparation of their 1989 return was                     
          complicated and that additional time was required to work on the            
          return does not establish reasonable cause for petitioners' late            
          filing.                                                                     
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          













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