- 7 -
entertainment expenses due to lack of substantiation; (ii) their
1990 Form 4868 was invalid; and that (iii) they are liable for
the addition to tax for failure to timely file their 1990 return
and the accuracy-related penalty. On December 21, 1992,
petitioners signed a Form 870, Waiver of Restrictions on
Assessment and Collection of Deficiency in Income Tax and
Acceptance of Overassessment for 1990. Respondent referred the
case to respondent's Appeals Office and issued a notice of
deficiency for 1990 on October 8, 1993. Petitioners filed their
petition for 1990 (docket No. 222-94) on January 3, 1994.
2. Petitioners' 1991 Tax Year
a. Application for Extension of Time To File for 1991
Petitioner prepared and petitioners filed a Form 4868 on
April 15, 1992, seeking to extend the time to file their 1991
return by 4 months to August 17, 1992. On it, petitioners
estimated that their total tax liability for 1991 was $9,800.
They reported that they had made estimated tax payments of $4,800
and had a balance due of $5,000, which they paid with the Form
4868.
b. Petitioners’ Federal Income Tax Return for 1991
Petitioner prepared petitioners’ 1991 income tax return.
Respondent received petitioners' income tax return for 1991 on
August 20, 1992. On that return, petitioners reported that they
received $105,322 in income from petitioner’s law firm and that
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011