William O. Harrison - Page 13

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             following reason why the extension was needed:  "[t]he                   
             taxpayer's C.P.A. has currently been experiencing an                     
             extremely heavy workload.  Although additional staff have                
             been employed, they have been unable to complete all                     
             returns."                                                                
                  On or about October 17, 1989, petitioners filed their               
             joint individual income tax return for 1988 on Form 1040,                
             U.S. Individual Income Tax Return.  They paid $101,093 with              
             the return.  This amount consists of total tax of $96,418,               
             less Federal income tax withheld of $1,408, plus a penalty               
             for underpayment of estimated tax reported on Form 2210,                 
             Underpayment of Estimated Tax by Individuals and                         
             Fiduciaries, in the amount of $6,083.                                    
                  On the Schedule E, Supplemental Income Schedule, filed              
             with their return, petitioners reported net income from the              
             Houston firm in the amount of $120,374, consisting of the                
             income reported on the Schedule K-1 sent by the firm to                  
             Mr. Harrison, $261,309, less aggregate expenses of                       
             $140,935.  On the Schedule F, Farm Income and Expenses,                  
             filed with their return, petitioners reported net farm                   
             profit of $287,789 from the cattle feeding business.                     
                  Petitioners' 1988 return included a Form 6252,                      
             Installment Sale Income, and a Form 8308, Report of a Sale               







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