Patrick W. Healey and Nancy L. Marshall - Page 4

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               Petitioner is an attorney and senior partner in the law firm           
          Healey & Wieland in Lincoln, Nebraska.  He has had more than 30             
          years' experience as an attorney, specializing in litigation.  He           
          was a partner at his law firm during the years in issue.  He had            
          access to all financial records of his law firm.                            
               Petitioner received draws from his law firm of $106,250 in             
          1990, $93,000 in 1991, and $144,120 in 1992.  Petitioner                    
          entertained clients as part of his business.                                
               Petitioner reached age 59� in 1990, which entitled him to              
          receive a $35,000 distribution from his law firm’s pension fund.            
          He received that amount during 1990 and deposited it in his bank            
          account.  Petitioner knew that he was required to report the                
          $35,000 as income on his tax return.  When he prepared his 1990             
          income tax return in August 1991, he did not remember in which              
          year he had received the distribution.  He did not check his                
          records to see when he had received it.                                     
               Petitioner wife is an artist, musician, and teacher.  She              
          held shows and entertained clients during the years in issue.               
          B.   Petitioners’ Application for Extension of Time To File                 
               Income Tax Returns                                                     
               1.   Petitioners' 1990 Tax Year                                        
                    a.   Application for Extension of Time To File                    
               Petitioner’s law firm had not prepared its partnership tax             
          return for 1990 by April 15, 1991.  On April 15, 1991, petitioner           
          prepared and petitioners filed a Form 4868 in which they                    




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