Charles R. Godwin et al. - Page 16

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          return were not “normally” due on October 15, 1998, but instead             
          on April 15, 1998.  However, respondent concedes that the news              
          release may have confused petitioners and for that reason                   
          concedes petitioners have reasonable cause under section                    
          6651(a)(1) and (2) for failing to file and pay for the period               
          October 15 to November 16, 1998.                                            
               Respondent assessed the section 6651(a)(1) addition to tax             
          for late filing for the period November 17 through December 21,             
          1998.  Respondent did not assess the section 6651(a)(2) addition            
          to tax for late payment from October 15 to November 16, 1998;               
          instead, respondent assessed the late payment addition for the              
          period April 16 through October 15, 1998, and the period November           
          17, 1998, to the date of payment by petitioners.                            
          4.  Late Payment of Tax                                                     
               a.  Failure To Pay Estimated Tax                                       
               Petitioners first failed to satisfy their tax obligations by           
          failing to pay any 1997 estimated tax as required by section                
          6654(a).  Petitioners argue in their brief, without explanation,            
          that respondent should have exercised his authority to waive the            
          section 6654(a) addition to tax because this is a case where, by            
          reason of a casualty or disaster, the imposition of that addition           
          to tax would be against equity and good conscience.  See sec.               

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