Patrick W. Healey and Nancy L. Marshall - Page 9

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          made when they filed the Form 4868, they reported that they had a           
          balance due of $13,776.33, which they paid with the return.                 
               4.   Audit of Petitioners’ 1991 and 1992 Returns                       
               On September 26, 1994, respondent's auditor wrote a letter             
          to petitioners enclosing a report recommending additions to tax             
          under section 6651(a)(1) in the amount of $3,375 for 1991 and               
          $2,404 for 1992.  The letter said the 1991 and 1992 returns had             
          the same disputed Form 4868 issue that was present on                       
          petitioners’ 1990 return, and that respondent’s auditor wanted to           
          keep the 3 years together.                                                  
               Respondent issued a notice of deficiency for 1991 and 1992             
          on December 19, 1994.  Petitioners filed the petition for tax               
          years 1991 and 1992 (docket No. 2613-95) on February 16, 1995.              
               5.   Summary                                                           
               The following compares the amount of tax liability                     
          petitioners estimated on Forms 4868 for the years in issue with             
          the amounts they reported on Forms 1040 or have otherwise                   
          conceded for those years:                                                   
                                                  Tax Liability                       
                         Tax Estimated Tax Reported    Conceded by                    
               Year      on Form 4868   on Form 1040   Petitioners                    
               1990      $6,000         $18,773.21     $31,856                        
               1991      9,800          24,865.52      25,118                         
               1992      22,000         35,776.33      35,776                         









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