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U.S. Individual Tax Return). There is no evidence as to what
addresses, if any, were listed on the Forms 4868 so filed.
Further, no remittance accompanied any of the Forms 4868.
Petitioner filed his extension requests with respondent's
various service centers and district offices as follows:
Year Location Where Form 4868 Was Filed
1987 Ogden, Utah
1988 Ogden, Utah
1989 Omaha, Nebraska, district office
1990 Helena, Montana, district office
1991 Ogden, Utah, service center
1992 Austin, Texas, service center
1993 Austin, Texas, service center
1994 Oklahoma City, Oklahoma, district office
Respondent's internal procedures regarding requests for
extensions mandate the following:
(1) At the time a service center receives a Form 4868, the
Social Security number is matched against the taxpayer's name;
(2) a computer entry is made noting receipt of the request
for extension;
(3) no other information is entered into the computer,
unless a remittance accompanies the request. Specifically, no
entry or change is made if the address on the request for
extension form is different from the taxpayer's address on file.
A taxpayer's signature need not accompany the request. The
request may therefore be filed by a return preparer without the
taxpayer's knowledge. Hence, as a matter of policy, respondent
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