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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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