Jane B. Oliver and Robert P. Oliver - Page 20

                                         20-  -                                        
               In the notice of deficiency, respondent disallowed the                 
          deductions for self-employment tax claimed by petitioners on                
          their 1990 and 1991 returns in the amounts of $7,849 and $10,246,           
          respectively, stating that deductions are allowed for only one-             
          half of self-employment taxes paid and that petitioners had                 
          previously been allowed to deduct one-half of the amounts they              
          paid in self-employment taxes.                                              
          Filing of Federal Income Tax Returns for 1990 and 1991                      
              Petitioners made estimated tax payments in the total amount            
          of $7,711.20 for 1990.  On or before April 15, 1991, petitioners            
          filed Form 4868, Application for Automatic Extension of Time to             
          File U.S. Individual Income Tax Return, requesting an automatic             
          4-month extension of the due date of their 1990 return.  No                 
          payment of tax accompanied their extension request.  Respondent             
          received petitioners' 1990 return on August 19, 1991.                       
               Petitioners made estimated tax payments in the total amount            
          of $10,246.60 for 1991.  On or before April 15, 1992, petitioners           
          filed Form 4868, Application for Automatic Extension of Time to             
          File U.S. Individual Income Tax Return, requesting an automatic             
          4-month extension of the due date of their 1991 return.  No                 
          payment of tax accompanied their extension request.  Respondent             
          received petitioners' 1991 return on July 20, 1992.                         
               In the notice of deficiency dated August 11, 1994,                     
          respondent stated:                                                          
               Your income tax returns for the tax years 1990 and 1991                
               were not filed within the time prescribed by law.  The                 



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