William O. Harrison - Page 14

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             or Exchange of Certain Partnership Interests.  These forms               
             state that a sale of Mr. Harrison's partnership interest in              
             the Houston firm took place on October 25, 1988, for an                  
             "estimated" selling price of $3,740,000.  Form 6252 also                 
             reports a cost or other basis in the partnership interest                
             of $195,351.  Petitioners did not report the $500,000                    
             payment that Mr. Harrison received in 1988 from the                      
             partnership.  They treated this payment as a loan, rather                
             than as income.                                                          

             Petitioners' Joint Return for 1989                                       
                  In April 1990, Mr. Whittington and Ms. Ruble prepared               
             and filed, on petitioners' behalf, a Form 4868 requesting                
             an automatic extension of time to file petitioners' 1989                 
             return.  The Form 4868 states that petitioners' total                    
             income tax liability for 1989 is $2,200, that they had                   
             Federal income tax withheld for the year of $2,200, and                  
             they had a balance due of zero.  The Form W-2, Wage and                  
             Tax Statement, issued to petitioner's wife for 1989 by                   
             her employer reports $2,374 in Federal income tax withheld,              
             and respondent's records show a payment in the same amount.              
             The record of this case does not explain why $2,200, rather              
             than $2,374, was entered on Form 4868.                                   








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