Walter Raymond Wilkerson and Susan Gee Wilkerson - Page 5

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          here have stipulated that petitioners' 1988 and 1989 joint                  
          Federal income tax returns were not received by respondent until            
          more than 5 months after their due dates, as extended.                      
          Petitioners, both of whom are experienced tax return preparers,             
          testified that they had also timely mailed returns to respondent,           
          and the returns that were received by respondent had been sent in           
          response to notices from respondent.  Respondent had no record of           
          receiving any returns from petitioners for 1988 or 1989, other              
          than the ones that were untimely received and the unsigned                  
          version that was received by respondent's agent.  The unsigned              
          return received by respondent's agent would have also been more             
          than 5 months delinquent on the date received.                              
               We do not accept petitioners' uncorroborated testimony that            
          they had timely mailed returns to respondent.  They did not                 
          provide any details concerning the preparation and mailing of the           
          returns and, because they also failed to file State returns,                
          cannot corroborate the existence of a Federal return's having               
          been attached to timely State returns for the same taxable                  
          periods.  Petitioners' suggestion that respondent did not receive           
          their allegedly timely filed returns 2 years in a row is                    
          uncorroborated and not credible.  Accordingly, we hold that                 
          petitioners are liable for 25-percent additions under section               
          6651 for failing to timely file their 1988 and 1989 joint Federal           
          income tax returns.                                                         

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