Paul A. and Marilyn J. Grothues - Page 11




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                                        1993                                          
                           Tax         Penalties    Interest      Fees                
          3d-Q 1985      $22,987.26   $11,658.13   $15,345.61    $9                   
          4th-Q 1984      11,695.00    18,540.11        ---  ---                      
          4th-Q 1986      32,903.30     3,278.74        358.88   ---                  
          Total        67,585.56    33,476.98     15,704.49     9                     
                                        1994                                          
                           Tax         Penalties    Interest      Fees                
          3d-Q 1985          ---      ($7,540.66)    $9,943.35    ---                 
          4th-Q 1984       ---        2,274.92      1,821.88     ---                  
          4th-Q 1986     $27,597.31       ---           ---      ---                  
          Total        27,597.31    (5,265.74)    11,765.23    ---                    
          The foregoing amounts total $116,776.03 for 1993 and $34,096.80             
          for 1994.                                                                   
               On April 15, 1996, petitioners filed Form 4868, Application            
          for Automatic Extension of Time to File U.S. Individual Income              
          Tax Return, extending the due date of their 1995 tax return to              
          August 15, 1996.  Petitioners claim they timely filed Form 2688,            
          Application for Additional Extension of Time to File U.S.                   
          Individual Income Tax Return, which extended the time to file               
          their 1995 tax return to October 15, 1996.  Petitioners mailed              
          their 1995 tax return to respondent on October 15, 1996, and                
          respondent received it on October 17, 1996.  Petitioners did not            
          attach a copy of Form 2688 to their 1995 tax return.  Exhibit 8-P           
          is a photocopy of the Form 2688 allegedly submitted by                      
          petitioners.  Respondent claims his records do not show receipt             
          of a Form 2688 from petitioners.                                            






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