- 20 - Petitioners filed a Form 2688, Application for Additional Extension of Time to File U.S. Individual Income Tax Return dated August 9, 1991, requesting an additional two-month extension of time to file their 1990 return. That application indicated that petitioners needed the additional time to "collect and summarize the information necessary to file an accurate return." That application was not signed by petitioners, was signed by "Edward A. Cronick CPA" as preparer of the application, and was sent to the Service. Petitioners filed a Federal income tax return for 1990 dated October 14, 1991. In that return, petitioners reported total salaries of $359,962. The portion of those reported salaries that was attributable to petitioner's legal practice was $349,000. In their 1990 return, petitioners reported a loss of $48,082 attributable to petitioner's rental activity at Crest- wood. Petitioners used that reported loss of $48,082 to offset other income reported in their 1990 return. Petitioners' 1990 Federal income tax return showed a tax liability of $70,742. That return was signed by petitioners as taxpayers and was signed by "Edward A. Cronick, CPA" as return preparer. Petitioner did not have any formal tax or accounting train- ing. However, petitioner was a sophisticated businessman and had been involved in several tax shelters that were challenged by the Service. In addition, during the board meeting held in JanuaryPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011