Patrick W. Healey and Nancy L. Marshall - Page 13

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          issue and that he received from the pension distribution in 1990.           
          Those amounts would have enabled petitioners to estimate their              
          tax liability for the years in issue far more accurately than               
          they did.  Petitioner’s draws and the income that he reported               
          from his law firm are as follows:                                           
                                        Income From                                   
                    Year      Draws        Law Firm                                   
                    1990      $106,250      $110,615                                  
                    1991      93,000       105,322                                    
                    1992      144,120       141,244                                   
               Petitioners did not follow the instructions on the Forms               
          4868 for 1990.  Line 1 of Form 4868 calls for the total tax                 
          liability for 1990 that the taxpayer expects to enter on his or             
          her individual income tax return.  For 1990, petitioners did not            
          make an entry on line 1 of Form 4868.  One could infer that                 
          petitioners made a tax liability estimate of $6,000 based on                
          the Form 4868 by adding the balance due ($1,200) to the total               
          payments and credits ($4,800).  However, $6,000 would not have              
          been a reasonable estimate; $6,000 is less than one-fifth of the            
          1990 tax liability ($31,856) to which they later agreed.  For               
          1991, petitioners’ estimate of their tax was about two-fifths of            
          their liability as reported on their income tax return, and for             
          1992, their estimate was about two-thirds of their liability as             
          reported on their income tax return.  See table at par. B-5 of              
          the Findings of Fact, p. 9.  Petitioners did not make a bona fide           
          attempt to base their estimate on information that was reasonably           





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