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10:45 p.m. on April 15, 1998, in an envelope that also contained
petitioners’ completed 1997 Form 4868, Application for Automatic
Extension of Time to File U.S. Individual Income Tax Return. Mr.
Huff testified that he mailed this envelope by placing it in a
post office box at a post office near his home in Chino Hills,
California. Respondent’s records indicate that his department in
Fresno, California, received petitioners’ 1997 tax return on
April 23, 1999, and respondent filed that return as of that date.
Respondent mailed the subject notice of deficiency to petitioners
on March 7, 2002.
Petitioners’ 1997 Form 4868 is a one-page document on which
petitioners listed their names, address, Social Security numbers,
and numeric answers to requested information concerning their
1997 Federal income tax. The requested information was “4 Total
tax liability for 1997", “5 Total 1997 payments”, and “6
Balance. Subtract 5 from 4". Petitioners answered that their
total tax liability for 1997 was “15,800", that their total 1997
tax payments equaled “15,800+”, and that their balance was zero.
All of the information that petitioners listed on their 1997 Form
4868 was written by hand. Petitioners requested through this
Form 4868 an extension of time until August 15, 1998, to file
their 1997 Federal income tax return. Respondent filed this Form
4868 as of April 15, 1998.
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