Charles R. Godwin et al. - Page 7

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               5.  * * * The year to year fluctuations in our income                  
               and expenses have necessitated requests for extensions                 
               of time to file and pay tax in the past.  We have                      
               always fulfilled our responsibility in this regard with                
               your kind assistance and cooperation.  We fully intend                 
               to maintain and pursue that excellent working                          
               relationship.                                                          
               In a September 15, 1998, letter, MSC informed petitioners it           
          could not grant their request for the additional extension                  
          because it had no record of having granted petitioners an                   
          original 4-month extension of time for filing.  MSC also                    
          requested a copy of the Form 4868 petitioners claimed they had              
          filed.                                                                      
               On October 6, 1998, the IRS issued a news release (the news            
          release) applicable to taxpayers residing in Escambia County                
          affected by Hurricane Georges that stated:  “most tax returns and           
          payments that normally would be due on October 15 will not be due           
          until November 16.”                                                         
               By letter dated November 16, 1998, petitioners provided MSC            
          a copy of an April 15, 1998, letter in which they confirmed                 
          mailing a Form 4868 as an extension of time “to file the federal            
          income tax return Form 1040 and to pay the tax due.”  The Form              
          4868 allegedly mailed on April 15, 1998, reported the following             
          regarding petitioners’ 1997 tax liability:                                  











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