Marvin W. and Kathryn A. McPike - Page 8

                                        - 8 -                                         
          lease the containers.  Pursuant to this agreement, GD&L was to              
          receive an annual lease management fee of $1 plus 15 percent of             
          the revenues generated by leasing petitioners' containers.                  
          Petitioner does not recall making any payments on the promissory            
          notes nor for any management fees.                                          
               Petitioners received income and expense statements related             
          to their container leasing investment.  Because petitioners did             
          not understand the documents, they took them to Lukensow for use            
          in the preparation of their tax returns.                                    
               On the Schedule E attached to their 1983 Federal income tax            
          return, petitioners reported ordinary losses of $33,758 from                
          Kathmar.  On Form 3468 petitioners computed an ITC in the amount            
          of $20,000.  Petitioners carried this $20,000 credit back to                
          taxable years 1980 and 1981 for refunds in the amounts of $8,698            
          and $11,311, respectively.                                                  
               Based on Lukensow's advice, petitioners filed Form 4868,               
          Application for Automatic Extension of Time, on April 12, 1985,             
          for an automatic extension until August 15, 1985, to file their             
          1984 Federal income tax return.  Petitioners gave Lukensow all              
          their tax papers, and he prepared the Form 4868.  On that form,             
          petitioners estimated their 1984 Federal income tax liability to            
          be $5,077, of which $4,551 had been withheld by Mrs. McPike's               
          employer and a life insurance company.  Petitioners filed Form              
          4868 and enclosed a check in the amount of $526.  Thereafter,               
          they sent by certified mail their 1984 Federal income tax return            




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  Next

Last modified: May 25, 2011