- 19 - On April 16, 1990, petitioners filed an application for an automatic extension of time to file their individual return for 1989 and paid the estimated tax due. On August 14, 1990, petitioners requested an additional extension of time to file their return until September 25, 1990. Respondent granted this extension application on August 30, 1990. Petitioners' Form 1040, U.S. Individual Income Tax Return, was signed on October 15, 1990, and stamped received by respondent's Austin, Texas, Service Center on October 22, 1990. We note that respondent did not determine an addition to tax for late filing with respect to petitioners' 1989 return. On their return, petitioners valued their SWI stock for section 83(b) purposes at $60.98 per share. Thus, petitioners did not report any income on their 1989 return with respect to petitioner's purchase of 500 shares of SWI stock. On April 4, 1990, petitioner purchased an additional 25 shares of SWI stock for $60.98 per share. Petitioners thereafter made a section 83(b) election with respect to these additional shares, in which they reported the fair market value of the stock to be $2,600 per share. This second section 83(b) election is not at issue in this case.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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