K & M La Botica Pharmacy, Incorporated, Et Al. - Page 5

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               For 1997, Ahmed is liable for the section 6651(a)(1)                   
          addition to tax.                                                            

          Ahmed 1998 Section 6651(f) Addition to Tax                                  
               Ahmed now alleges, for the first time, that he obtained an             
          extension until October 15, 1999, to file his and his wife’s 1998           
          joint Federal income tax return.  Because he filed the 1998                 
          return on September 24, 1999, Ahmed contends that he should not             
          be held liable for a section 6651(f) fraudulent failure to file             
          addition to tax.                                                            
               In his petition, although Ahmed made a general claim that he           
          timely filed his Federal income tax returns for 1995 through                
          1998, Ahmed did not specifically assign error to respondent’s               
          imposition of the section 6651(f) addition to tax for 1998 based            
          on an alleged extension of time to file.                                    
               Further, at trial, on brief, and in his proposed findings of           
          fact, Ahmed did not assert that he obtained a valid extension of            
          time to file his 1998 joint Federal income tax return, nor did              
          Ahmed argue that the alleged extension made imposition of the               
          section 6651(f) addition to tax inappropriate.                              
               We conclude that Ahmed abandoned this argument.  See Mendes            
          v. Commissioner, supra.                                                     
               Further, to be valid, Form 4868, Application for Automatic             
          Extension of Time To File U.S. Individual Income Tax Return,                
          must show the full amount properly estimated as tax for the year.           





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