Charles R. Godwin et al. - Page 6

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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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