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whether petitioner’s tax returns for the years in issue were filed
(1) on or about December 4, 1998, (2) on or about October 15 of the
respective year (the last day of the extended filing period), or
(3) some other date or dates. The parties understand that allow-
ability of credits or refunds of overpayments for 1993 and 1994 and
liability for additions to tax for 1995 will be resolved by our
determinations as to dates of filing.
FINDINGS OF FACT
Some of the facts have been stipulated; the stipulations and
the stipulated exhibits are incorporated herein by this reference.
When the petition was filed in the instant case, petitioner
resided in Clarksville, Maryland. For all relevant times,
petitioner has been married to Evalyn V. Jacobson, hereinafter
sometimes referred to as Evalyn.
In or about the 17th week of 1993, respondent posted as of
April 18, 1993, petitioner’s $7,500 payment of 1993 estimated tax.
In or about the 26th week of 1993, respondent posted as of
June 19, 1993, petitioner’s $10,000 payment of 1993 estimated tax.
In or about the 39th week of 1993, respondent posted as of
September 18, 1993, petitioner’s $15,000 payment of 1993 estimated
tax.
In or about the 6th week of 1994, respondent posted as of
January 15, 1994, petitioner’s $20,000 payment of 1993 estimated
tax.
In or about the 19th week of 1994, respondent posted as of
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