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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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Last modified: May 25, 2011