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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.
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