- 8 -
year. Typically, they would discuss by telephone the
changes to the taxable income reported on petitioners' last
tax return that were necessary to estimate petitioners'
taxable income for the calendar year under review. During
these discussions, Ms. Ruble would review petitioners' last
tax return, and Ms. Cates would review petitioners' books
and records, and other tax information. Ms. Ruble would
make an adding machine tape that showed the additions to
and subtractions from the taxable income reported on
petitioners' last tax return. The total on the tape was
petitioners' estimated taxable income for the calendar year
under review.
During the years in issue, Mr. Whittington's office
had a policy concerning the manner in which Forms 4868,
Application for Automatic Extension of Time To File U.S.
Individual Income Tax Return, were to be completed if a
client had no taxable income for the year. In that event,
the accountants in Mr. Whittington's office would enter the
amount of any income tax withheld, plus any estimated tax
payments, on the Form 4868 on the line provided for the
taxpayer's total tax liability, and they would show a
balance due of zero, rather than a negative amount.
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Last modified: May 25, 2011