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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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