Charles Wendell Harkey, Sr. and Barbara Anne Harkey - Page 4

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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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