- 19 -
cated on line 1 a zero estimated Federal income tax liability for
petitioners for that year, was signed by petitioners, and was
sent to the Internal Revenue Service (Service).
Petitioners filed a Federal income tax return for 1989 dated
October 15, 1990. In that return, petitioners reported total
salaries of $315,662. The portion of those reported salaries
that was attributable to petitioner's legal practice was
$311,000. In their 1989 return, petitioners reported a loss of
$45,666 attributable to petitioner's rental activity at Crest-
wood. Petitioners used that reported loss of $45,666 to offset
other income reported in their 1989 return. Petitioners' 1989
return showed a tax liability of $66,958. That return was signed
by petitioners as taxpayers and was signed by "Edward A. Cronick,
CPA" as return preparer.
Petitioners filed an application for automatic extension
dated April 12, 1991, requesting a four-month extension of time
to file their Federal income tax return for 1990 (1990 return).
Line 1 of that application was virtually identical to line 1 of
the application for automatic extension for 1989 and provided
exactly the same caution. Petitioners' application for automatic
extension for 1990 indicated on line 1 a zero estimated Federal
income tax liability for petitioners for that year, was not
signed by petitioners, was signed by "Edward A. Cronick CPA" as
preparer of the application, and was sent to the Service.
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: May 25, 2011