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petitioners an extension to June 15, 1982, a further extension to
August 15, 1982, and a final extension to October 15, 1982.
Petitioners filed their 1981 tax return on April 14, 1988, after
the notices of deficiency were issued and the petition was filed.
On their 1981 tax return, petitioners reported (1) $44,107
gross income and $24,585 net profit from Associates, (2) $15,298
gross income and $16,285 net loss from Robert Iles Computer
Service, (3) $68,529 gross income and net profit from Robert's
role as business manager of Riago Trust, (4) $35,451 gross income
and $4,770 net loss from Maximum Management, (5) $35,648 as
grantor trust income from Riago Trust, and (6) $10,953 long-term
capital gain from the attempted sale of SSC. Supra M. First Sale
of Interest in Structured Shelters of Cincinnati. Petitioners
reported their total tax liability as $5,501 ($1,304 income tax,
$2,762 self-employment tax, and $1,435 alternative minimum tax).
3. Petitioners' 1982 Tax Return
On April 15, 1983, petitioners filed for an extension of
time to file their 1982 tax return. Respondent granted to
petitioners an extension to August 15, 1983. Petitioners did not
seek, and respondent did not grant, any additional extensions for
petitioners' 1982 tax return. Petitioners filed their 1982 tax
return on April 14, 1988, after the notices of deficiency were
issued and the petition was filed.
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