- 6 - Counties, as disaster areas as a result of Hurricane Georges, which occurred in September 1998. Petitioners’ 1997 Federal income tax return was originally due April 15, 1998. In an August 14, 1998, letter to the IRS Memphis Service Center (MSC), petitioners stated they had filed timely a Form 4868, Application for Automatic Extension of Time to File U.S. Individual Income Tax Return, to extend the time to file their 1997 return to August 15, 1998. In the same letter, petitioners requested an additional 4-month extension to December 15, 1998, to file their 1997 return and pay the taxes due. Petitioners asserted the following reasons for their request: 1. * * * We have experienced some personnel changes in connection with the bookkeeping, accounting, and tax preparation function of our law practice. For this reason, we have incurred considerable delay in recording, documenting, compiling, classifying and reviewing the necessary financial data from which the returns could be prepared. * * * 2. During calendar year 1997, we earned the highest income we have ever earned and accordingly, experienced the highest tax liability, the exact amount of which we are still in the process of determining. We need the additional time to prepare and file reasonable accurate returns and to pay the tax. 3. Substantial earnings from 1997 were placed in real estate, part of which was earmarked or designated to be used to pay the tax liability. Several such parcels of real estate are listed for sale and we expect them to sell and generate funds for payment of tax within the next four (4) months. 4. Payment of tax at this time would create an unreasonable hardship and borrowing would create extraordinary expenses which would impair the cash flow in the operation of the law practice.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011