7. Last year, your client, Roberto Dinero, mailed an automatic extension for this tax return on April 15. He enclosed a check for $10,000 with the extension request. The IRS cashed the check on April 28. Later, the IRS assessed Roberto late filing penalties of $2,900 because they claim he did not mail the extension request on time. On the same date, Roberto mailed an income tax extension request and check to the state of California. The California check was cashed on April 16. You requested that the IRS send you a copy of the extension request envelope showing the postmark; however, the IRS has lost it. The IRS recently attached Roberto's bank accormt for the $2,900, thereby seizing the funds directly. You have known Roberto for years, and he could be described as a good, law- abiding, taxpaying citizen. He always pays his taxes on time, has never been in trouble with the IRS, and is not a tax protester. Roberto asks you to recommend whether he should engage a tax attorney and sue for a refund, knowing that the legal fees for such an action will probably exceed $10,000. What is your advice? Key words used in search: failure to file [20 envelope Citation: Issue: Facts: Holding: Analysis