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this was stated to be until May 5, 1989. The only documentary
evidence that petitioners presented on this point is a letter
attached to their 1987 tax return, as follows (emphasis in
original):
Melvin J. & Carolyn A. Laney
1515 Spencerville Rd.
Spencerville, Md. 20868
November 9, 1988
Director
Internal Revenue Service
Philadelphia, Pa. 19255
Dear Director:
Re: Verification of Special Extension to File 1987
Return for Account # 215 38 2691
On August 15, 1988 we filed Form 2688 plus a special
request to file our 1987 return by May 5, 1989. As part of
our special request we enclosed a copy of our May 5, 1988
Md. Tax Court opinion ruling in our favor. The Md.
Comptroller had taken no action on this ruling and we
requested a special extension. Yesterday we received a
notice from your office granting our request for “Maximum
time allowed”.
Today we called 488-3100 and spoke with a Mr. Hill in
the Problem Resolution Office and then with a Mr. Wilson of
the Accounts Office. Mr. Wilson assured us that we could
assume the words “Maximum time allowed” applied to our
special request and not to the standard Form 2688 extension
time. The time period for Form 2688 expired last month.
We are writing this letter to verify approval of our
special request based on the Maryland Tax Court opinion
previously enclosed. The final resolution of this case will
effect how our Federal Income Tax/Md. return is completed.
We will owe no federal tax and will receive a refund for
1987.
Sincerely,
Melvin J. Laney
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