Patrick W. Healey and Nancy L. Marshall - Page 8

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          their tax liability was $24,865.52.  After subtracting withheld             
          and estimated tax and tax paid with the Form 4868, they reported            
          that they had a balance due of $14,849.52, which they paid with             
          the return.                                                                 
               Respondent issued a notice of correction of petitioners'               
          1991 tax return on October 5, 1992, making certain adjustments              
          and imposing penalties and interest.  Petitioners filed an                  
          amended 1991 return on January 29, 1993, on which they reported a           
          corrected tax liability of $25,118.                                         
               3.   Petitioners' 1992 Tax Year                                        
                    a.   Application for Extension of Time To File for 1992           
               Petitioner prepared and petitioners filed a Form 4868 for              
          1992 on April 15, 1993, in which they estimated that their total            
          tax liability for 1992 was $22,000.  They reported that they had            
          made estimated tax payments of $12,000 and had a balance due of             
          $10,000, which they paid with the Form 4868.                                
                    b.   Petitioners’ Federal Income Tax Return for 1992              
               Petitioner prepared petitioners’ joint Federal income tax              
          return for 1992.  Respondent received it on August 23, 1993.  The           
          envelope in which the return was mailed was postmarked August 16,           
          1993.  They reported that they received income of $141,244 from             
          petitioner’s law firm and had a tax liability of $35,844.53.                
          After subtracting withheld and estimated tax and the payment they           







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