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Petitioners resided in Rancho Santa Margarita, California,
at the time that the petition was filed with the Court.
A. Petitioners’ Income Tax Returns
Petitioners filed Federal income tax returns for each year
in issue reporting tax due as follows:
Extension of
Tax Year Date Filed Time to File Tax Due
1995 04/15/1996 -0- $4,528
1996 09/22/1997 08/15/1997 2,327
1998 12/29/1999 08/15/1999 10,965
1999 10/15/2000 08/15/2000 2,431
2000 10/12/2001 10/15/2001 26,144
2001 04/15/2002 -0- 1,826
At the time that they filed each return, petitioners did not pay
the tax shown as due on the return.
Based on the returns filed by petitioners, respondent
assessed the tax shown as due on each return, statutory interest
for the years in issue, an addition to tax for failure to timely
file a return under section 6651(a)(1) for 1996, 1998, and 1999,
an addition to tax for failure to timely pay tax under section
6651(a)(2) for the years in issue, and an addition to tax for
failure to pay estimated tax under section 6654 for the years in
issue.
On May 27, 1999, petitioners entered into an installment
agreement for 1995 and 1996, but defaulted on April 29 and March
25, 2002, respectively. On January 20, 2002, petitioners entered
into an installment agreement for 1998, 1999, and 2000, but
defaulted on April 29, 2002.
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