-35- Rolls Royce. The capital contributions by SSI on behalf of petitioners are 1982 income to petitioners. S. Tax Returns Petitioners are cash basis taxpayers. 1. Petitioners' 1980 Tax Return On April 15, 1981, petitioners filed for an extension of time to file their 1980 tax return. Respondent granted to petitioners an extension to June 15, 1981. Additional extensions for petitioners' 1980 tax return were neither sought by petitioners, nor granted by respondent. Petitioners filed their joint 1980 tax return on September 18, 1981. On their 1980 tax return, petitioners reported (1) $79,989 gross income and $71,154 net profit from Associates, (2) $19,010 gross income and $39,128 net loss from Robert Iles Computer Services, and (3) a $13,860 net loss from Robert Iles, et al. Petitioners reported their total 1980 tax liability as $5,541 ($1,283 income tax, $1,471 self-employment tax, and $2,787 tax from recomputing prior-year investment credit). Below their signatures, petitioners wrote the following: "This return was prepared under duress due to summons and it will be amended." However, petitioners never amended their 1980 tax return. 2. Petitioners' 1981 Tax Return On April 15, 1982, petitioners filed for an extension of time to file their 1981 tax return. Respondent granted toPage: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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