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The 1989 Federal income tax return was filed after the October
15, 1990, due date, as extended. On October 21, 1994, the
Bensons filed their 1993 Federal income tax return. On February
14, 1995, the Bensons filed their 1990 Federal income tax return
through respondent’s agent. The 1990 Federal income return was
filed after the October 15, 1991, due date, as extended.
On June 29, 1995, respondent issued Burton a notice of
deficiency for the tax years 1991 and 1992. On October 25, 1995,
the Bensons filed their 1994 Federal income tax return. On
November 27, 1995, respondent assessed a deficiency against
Burton for the 1992 tax year on the basis of a notice of
deficiency dated June 29, 1995. On December 13, 1995, the
Bensons filed their 1991 Federal income tax return. On January
1, 1996, respondent assessed a deficiency against Burton for the
1991 tax year on the basis of a notice of deficiency dated June
25, 1995. On March 5, 1997, the Bensons filed their 1992 Federal
income tax return.
(b) Eric B. Benson
On or about April 15, 1994, Eric requested an extension of
time to file his 1993 Federal income tax return. On October 17,
1994, Eric filed his 1993 Federal income tax return. On October
23, 1995, Eric filed his 1994 Federal income tax return.
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