Thomas B. Drummond - Page 15

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          1990.  Mr. McVeigh completed and filed on petitioner's behalf               
          Forms 4868 (Application for Automatic Extension of Time to File             
          U.S. Individual Income Tax Return (application for automatic                
          extension)) for those years that were dated April 11, 1990, and             
          April 5, 1991, respectively, signed by petitioner, and requested            
          a four-month extension of time until August 15, 1990, and August            
          15, 1991, respectively, within which to file his returns for                
          those years.  Line 1 of each of those applications required                 
          petitioner to make a reasonable estimate, based on the informa-             
          tion available, of his tax liability for the year for which he              
          was seeking an extension.  In arriving at the respective esti-              
          mated tax liabilities for 1989 and 1990 that Mr. McVeigh showed             
          on line 1 of petitioner's applications for automatic extension              
          for those years, Mr. McVeigh believed it reasonable, and so                 
          advised petitioner, that, given petitioner's situation, those               
          estimates be based on the tax liability shown in petitioner's               
          return for the year immediately preceding the year for which each           
          such application was being filed, provided that petitioner paid             
          each of those estimated tax liabilities by the time he filed each           
          such application.  Since the tax liabilities shown in peti-                 
          tioner's 1988 and 1989 returns were $9,041 and $9,043, respec-              
          tively, Mr. McVeigh entered on line 1 of petitioner's applica-              
          tions for automatic extension for 1989 and 1990 estimated tax               
          liabilities of $9,100 and $9,043, respectively.  Those respective           
          applications also indicated that for 1989 estimated tax payments            

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