Walter R. Huff and Lucy C. Huff - Page 2

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          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. and               






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