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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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