- 3 - 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011