Greg R. Vinikoor and Melissa D. Vinikoor - Page 19

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          can show that the failure to timely file the return was due to              
          reasonable cause and not willful neglect.  Sec. 6651(a).                    
               Petitioners were required to file a 1990 Federal income tax            
          return by April 15, 1991.  Secs. 6012, 6072.  Taxpayers, however,           
          may be granted reasonable extensions of time to file their                  
          returns.  Sec. 6081.  An automatic extension of time to file a              
          return extends the time to file 4 months from the date the return           
          was originally due.  Sec. 1.6081-4, Income Tax Regs.                        
               On April 15, 1991, petitioners filed a Form 4868 Application           
          for Automatic Extension of Time to File U.S. Individual Income              
          Tax Return for their 1990 Federal income tax return, on which               
          they claimed their tax liability to be zero. On August 13, 1991,            
          petitioners filed a Form 2688 Application for Additional                    
          Extension of Time to File U.S. Individual Income Tax Return for             
          their 1990 Federal income tax return, requesting an extension of            
          time until October 15, 1991.  Petitioners did not list any tax              
          due on the additional extension of time request.                            
               Petitioners did not file their 1990 Federal income tax                 
          return until October 18, 1991, listing an amount owed of $20,306.           
          On April 20, 1992, petitioners filed an amended 1990 return                 
          listing an increase in their total tax liability of $24,124, for            
          a total amount owed of $43,203 after withholding.                           
               Petitioners stipulated that they are liable for an addition            
          to tax pursuant to section 6651(a)(1) for 1990 insofar as it                





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