- 8 -
Actual legislation in Montserrat, however, restricting
activity of foreign owned banks and precluding ownership in
Montserrat of banks by foreign individuals was not enacted until
1991.
In September of 1989, Hurricane Hugo struck Montserrat
bringing with it 200-mile-an-hour winds that destroyed much of
the island, including the shared office in Montserrat of Guardian
Bank, Guardian Services, and Stanford Financial. All of the
furniture in the office was destroyed, including a safe
containing records of Guardian Bank, Guardian Services, and
Stanford Financial.
On October 25, 1990, petitioners filed their 1989 joint
Federal income tax return.
On March 18, 1991, petitioner filed a 1990 corporate Federal
income tax return of Stanford Financial (Form 1120F), and on
September 19, 1991, pursuant to automatic 6-month extensions of
time for filing, petitioner filed 1990 corporate Federal income
tax returns of Guardian Bank and of Guardian Services (Forms
1120F).
Petitioners requested and apparently received an automatic
extension of time to file until August 15, 1991, their 1990 joint
Federal income tax return. The evidence does not indicate when
petitioners mailed to respondent their 1990 joint Federal income
tax return. Although petitioners apparently signed their 1990
joint Federal income tax return on November 5, 1991, respondent
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