Charles R. Godwin et al. - Page 8

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          Part II  Individual Taxes                                                   
               4  Total tax liability for 1997              $ unknown                 
               5  Total 1997 payments                         5,013.80                
               6  Balance.  Subtract 5 from 4                 unknown                 
          Part III  Gift/GFT Tax [No entries]                                         
          Part IV  Total                                                              
               9  Total liability.  Add lines 6,7, and 8    $ unknown                 
               10 Amount you are paying                       0.00                    
          Petitioners did not pay any Federal income tax when they filed              
          Form 4868.  In the November 16, 1998, letter, petitioners                   
          asserted the following additional reasons for their request for             
          extension of time to December 15, 1998, to file their 1997 return           
          and pay the tax due:                                                        
               1.  The extraordinary events which occurred during the                 
               calendar year 1997 and subsequently.  These included                   
               very high income, investment in real estate which we                   
               intended to sell to pay taxes and which did not sell in                
               the manner, for the price and within time we had                       
               anticipated.                                                           
               2.  The preparation of the return required                             
               consideration of the casualty loss of our bay house                    
               near Fort Morgan as a result of Hurricane Danny in                     
               July, 1997.  Additionally, we suffered substantial                     
               damages to our home here in Atmore, Alabama and less                   
               severe damages to our law office here as a result of                   
               Hurricane Georges during the latter part of September,                 
               1998.  The aftermath of damage to our home, the                        
               necessary repair of which was not all covered by                       
               insurance, the electrical power outages at our office                  
               and at home frustrated our good faith efforts to file                  
               the return and pay the tax.                                            
               3.  We have additional personnel changes since August                  
               14, 1998, including the bookkeeper who was assisting                   
               with our tax records in the preparation of the return.                 
               4.  The law practice income which is our primary source                
               of income for 1998 has not reached the level of income                 








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