Mark N. Wright and Erica Y. Wright - Page 7

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          return, and they subsequently requested a further extension to              
          October 15, 2002.  On their first request for an extension,                 
          petitioners estimated their tax liability to be $23 and remitted            
          no payment.  Petitioners mailed their 2001 return on August 20,             
          2002, and respondent received it on August 23, 2002.                        
                    2. Wright & Associates’ Returns                                   
               Mr. Wright was responsible for filing Wright & Associates’             
          Federal tax returns for the years in issue.  Respondent received            
          Wright & Associates’ Form 1120S for its 1999 taxable year on                
          November 23, 2001.  Respondent received Wright & Associates’ 2000           
          Form 1120S on December 3, 2001.  Wright & Associates requested an           
          extension of time to file its 2001 Form 1120S to September 15,              
          2002.  Respondent received Wright & Associates’ 2001 Form 1120S             
          on August 23, 2002.                                                         
               On Schedule B, Other Information, of the 1999, 2000, and               
          2001 Forms 1120S, both cash and accrual were checked as the                 
          method of accounting.  Wright & Associates did not list any trade           
          notes or accounts receivables on its balance sheets or on                   
          Schedule L, Balance Sheets per Books, of its 1999, 2000, and 2001           
          Forms 1120S.                                                                
               C. Distributions                                                       
               During 1999, Wright & Associates distributed to petitioners            
          $64,601.  Wright & Associates also issued checks totaling $5,580            







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