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filing) and part III (extension for paying) “7-31-93” and “12-31-
93”, respectively. On the returned Form 4768 in light red ink
(1) lines were drawn through “7” and “31” in part II and these
numbers were replaced by “8” and “4”, respectively, and (2) lines
were drawn through “12”, “31”, and “93” in part III and these
numbers were replaced by “2”, “4” and “94”, respectively. Also,
on the returned Form 4768, part V, (1) item 1 (extension for
filing) is shown as approved and there is penciled in “080493”,
and (2) item 2 (extension for paying) is shown as approved and
there is penciled in “020494”. The heading of part V is printed
in boldface type as follows: “Notice to Applicant--To be
completed by Internal Revenue Service”. Finally, on the returned
Form 4768, part V, item 1 (extension for filing), there is
stamped in faint blue ink the following: THE MAXIMUM EXTENSION
ALLOWED FOR FILING IS 6 MONTHS. On the Form 4768, part II
(extension for filing), there are not any marks on the “93” that
Christy had typed in as part of the “7-31-93” requested
extension.
Christy interpreted the returned Form 4768 as having
extended the due date for filing to February 4, 1994. In late
1993 (after August 4, 1993) or early 1994 Christy told Hinz that
he had received an extension of time until February 4, 1994, to
file the estate tax return, and reminded Hinz that appraisals
were needed for the real estate. This was the first time that
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