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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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