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Background
Some of the facts have been stipulated, and they are so
found. Petitioners resided in Atlanta, Georgia, at the time that
their petition was filed with the Court.
A. Petitioners’ Liability for 1992
On or before April 15, 1993, petitioners filed Form 4868,
Extension of Time To File U.S. Individual Income Tax Return, and
were granted an automatic 4-month extension of time to file their
Federal income tax return for 1992. However, petitioners did not
file their 1992 Form 1040, U.S. Individual Income Tax Return,
until June 17, 1994, some 10 months after the due date as
extended. See secs. 6072(a); 6081(a).
On their 1992 income tax return, petitioners reported total
tax of $3,458, total payments of $0, and amount owed of $3,458.
Petitioners did not enclose payment with their return of any part
of the liability reported thereon.
On July 25, 1994, respondent assessed against petitioners
income tax in the amount of $3,458, an addition to tax under
section 6651(a)(1) for failure to timely file in the amount of
$778.05, an addition to tax under section 6651(a)(2) for failure
to timely pay in the amount of $276.64, and interest in the
amount of $379.45. On that same day, respondent sent petitioners
a notice of balance due, informing them that they had a liability
for 1992 and requesting that they pay it. Petitioners failed to
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Last modified: May 25, 2011