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Arkansas, to deliver the returns of petitioner for review and
signature.
Mr. Coy arrived at petitioner’s office between 8:45 and 9
p.m. Petitioner signed the returns in the presence of Mr. Coy
and Frances Robinette, petitioner’s wife and office manager.
After the clients signed their tax returns, Mr. Coy took the
signed returns from his clients so that he could mail them from
his office in Little Rock, Arkansas.
Mr. Coy returned to his office in Little Rock, Arkansas,
sometime after 11 p.m., but before midnight. Mr. Coy made a copy
of the signature page of petitioner’s 1998 return. Mr. Coy
affixed postage to the envelope containing petitioner’s 1998
return using a private postage meter. The postage from the
private postage meter displayed a postmark of October 15, 1999.
Before midnight, Mr. Coy placed the envelope containing
petitioner’s 1998 return in a U.S. Postal Service mailbox in the
building where his office is located.
At this same time, Mr. Coy mailed the returns of Mr. Sharp.
Mr. Sharp was not assessed late filing penalties or late payments
by the Internal Revenue Service (IRS) with respect to his 1998
individual income tax return.
Petitioner’s 1995, 1996, 1997, 1999, and 2000 Individual Income
Tax Returns
Petitioner received extensions to file his 1995 individual
income tax return on or before October 15, 1996. Petitioner’s
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Last modified: May 25, 2011