Questione giuridica chiave
Whether the taxpayers, not their trustee, were the proper parties in the recourse against the refusal to further extend the filing deadline.
Decisione estratta
The taxpayers themselves were the parties in the recourse, even though the extension reasons lay with their representative.
Motivazione estratta
The duty to file the tax return rests primarily with the taxpayer; representation does not shift that procedural position vis-à-vis the tax authorities.