- 21 -
Petitioners timely filed tax returns for 1986 and 1988.
Petitioners timely filed for an automatic extension of time,
until August 15, 1988, to file their 1987 tax return. On August
15, 1988, petitioners timely filed a request for a further
extension, until May 5, 1989, to file their 1987 tax return.
Petitioners were granted an extension only until October 17,
1988. Petitioners filed their 1987 tax return on May 11, 1989.
Petitioners did not file their 1987 tax return, or a “first”,
“initial”, or “preliminary” 1987 tax return, before the May 11,
1989, filing referred to supra.
After petitioners filed their petition in the instant case,
they dealt with an Appeals officer. After petitioner and the
Appeals officer failed to settle the case, petitioners sent a
letter to the Secretary of the Treasury, urging him to enter into
a section 7121 closing agreement with petitioners. The letter
and accompanying materials were referred to the Philadelphia
Internal Revenue Service Center. An employee at this Center
somehow came to the conclusion that the Appeals Office and
petitioner had entered into a binding settlement agreement and
thus a section 7121 closing agreement would not be appropriate.
Respondent did not audit petitioners’ 1983, 1984, and 1985
tax returns.
On May 5, 1988, the Maryland Tax Court issued an Order and
Memorandum of Grounds for Decision in a proceeding involving
Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: May 25, 2011