- 2 - Petitioner Deficiency Sec. 6651(a)(1) Sec. 6654(a) Barry Michelson $979 $244.75 -0- Shelley Michelson 50,870 8,168.00 $1,450 Pursuant to respondent's uncontested motion, the cases have been consolidated for "trial, briefing and opinion." At issue is whether either petitioner is entitled, under sections 6402 and 6511(a), to a refund of overpayment of taxes withheld from petitioner Shelley A. Michelson's wages, dividends, and interest. Petitioners will sometimes be referred to simply as Barry and Shelley, respectively. The facts have been stipulated.1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue. Petitioners are husband and wife. They resided in Stamford, Connecticut, when they filed their respective petitions in these cases. Petitioners filed a timely request for an automatic 4- month extension of time to file their 1991 return. As a result of the extension, their return was due on August 15, 1992, a Saturday. The following Monday, August 17, 1992, was not a legal holiday in the District of Columbia or the State of 1The Court ordered simultaneous briefs. However, although the Government filed its opening brief, the Court has been informed that petitioners do not intend to file any brief.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011