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
Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: May 25, 2011