- 2 - period of limitations under section 6501(a) has run as to their 1997 taxable year. We hold it has not. Unless otherwise noted, section references are to the applicable versions of the Internal Revenue Code. FINDINGS OF FACT Some facts were stipulated. The stipulated facts and the accompanying exhibits are incorporated herein by this reference. We find the stipulated facts accordingly. Petitioners resided in Montgomery, Texas, when their petition was filed. Petitioners filed with respondent a 1997 Form 1040, U.S. Individual Income Tax Return, using the filing status of “Married filing joint return” and reporting their “total tax” and “total [tax] payments” for the year as $13,340 and $16,327, respectively. The return consisted of seven single-sided pages. The information that petitioners furnished in the signature block on page 2 of the Form 1040 (i.e., signatures, date of signatures, and occupations) was all written by hand, as were two “X”s that were placed in the “No” blocks to questions requiring the checking of a “Yes” or “No” box. All other information petitioners reported on their 1997 return was typed. Petitioners reported on the 1997 return that they had each signed the return on April 15, 1998. Walter R. Huff (Mr. Huff) testified at trial that he mailed petitioners’ 1997 return to respondent between 10:30 p.m. andPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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