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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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