Patrick W. Healey and Nancy L. Marshall - Page 5

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          requested a 4-month extension of the time to file their 1990 tax            
          return.                                                                     
          The Form 4868 petitioners filed stated:                                     
               Total tax liability for 1990.  This is the amount you                  
               expect to enter on line 27 of Form 1040A, or line 54 of                
               Form 1040.  If you do not expect to owe tax, enter zero                
               (-0-) . . . . .                                                        
               Caution:  You MUST enter an amount on line 1 or your                   
               extension will be denied.  You can estimate this                       
               amount; but be as exact as you can with the information                
               you have.  If we later find that your estimate was not                 
               reasonable, the extension will be null and void.[1]                    
               Petitioners did not estimate their tax liability for 1990 on           
          line one of the Form 4868.  Petitioners reported that they had              
          paid estimated taxes of $4,800 and had a balance due of $1,200,             
          which they paid when they filed the Form 4868.                              
                    b.   Petitioners’ Federal Income Tax Return for 1990              
               Petitioner prepared petitioners’ Federal income tax return             
          for 1990.  Petitioners filed it on August 15, 1991.  They                   
          reported that petitioner’s income from his law firm was $110,615            
          and that petitioners’ tax liability was $18,773.21.  They                   
          subtracted their estimated tax payments and the payment they made           
          with the Form 4868, and reported a balance due of $12,773.21.               
               Petitioners deducted $3,580 for meals and entertainment                
          expenses on their 1990 return.  Petitioners did not keep                    



               1 The Forms 4868 that petitioners signed for 1991 and 1992,            
          discussed below, also contained this language.                              




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