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Respondent’s records show that, on August 22, 1988, it was
posted that petitioners’ request for further extension was
granted until October 17, 1988.
In evaluating the evidence we note the following:
(1) Petitioners appear to have made up their story
about a 1987 tax return filed on or about August 15,
1988.
(2) Petitioners have kept extensive tax-related
records dating back to 1977 but have not produced the
notice they received from respondent so that we could
view the language described in petitioners’ November 9,
1988, letter.
(3) Petitioners have not described with
particularity what they asked of respondent’s employees
in the telephone call described in petitioners’
November 9, 1988, letter.
Petitioners have to persuade us that it is more likely than
not that respondent’s employees advised petitioners that
petitioners had until May 5, 1989, to file their 1987 tax return,
that petitioners in fact relied on this advice, and that it was
reasonable for petitioners to rely on this advice.
We doubt the correctness of petitioners’ story; we doubt
that respondent’s employees really advised petitioners that the
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