Questão jurídica principal
Whether the taxpayers, not their trustee, were the proper parties in the recourse against the refusal to further extend the filing deadline.
Decisão extraída
The taxpayers themselves were the parties in the recourse, even though the extension reasons lay with their representative.
Fundamentação extraída
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.