- 47 - 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 thePage: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 Next
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