Melvin J. Laney and Carolyn A. Laney - Page 47

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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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