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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.
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