Thomas and Julia Bo - Page 3

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          time not specified in the record, petitioner wife had serious               
          medical conditions which prevented her from compiling that tax              
          data.                                                                       
               Petitioner suffered substantial personal injuries in an                
          automobile accident on December 13, 1996, which left him                    
          permanently 20 percent disabled.  During the 4 years after the              
          accident, petitioners struggled financially, were evicted from              
          two homes, and had one vehicle repossessed.                                 
          B.   Petitioners’ Federal Income Tax Returns and Payments                   
               Petitioners requested and received an extension of time to             
          October 15, 1992, to file their 1991 Federal income tax return.             
          Petitioners submitted $1,000 with that request.  They later                 
          reported a tax liability of $2,794 for 1991.                                
               Petitioners did not request or receive extensions of time in           
          which to file their Federal income tax returns for 1992-94.                 
          Petitioners requested and received an extension of time to                  
          October 15, 1996, to file their 1995 return.  Petitioners                   
          submitted $435 with this request.  They later reported a tax                
          liability of $544 for 1995.                                                 
               Petitioners untimely filed their 1991-95 Federal income tax            
          returns on April 17, 1997.  H & R Block prepared those returns.             
          On those returns, petitioners reported the following income tax             
          liabilities:                                                                







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