William O. Harrison - Page 15

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                  In computing petitioners' estimated tax liability for               
             1989, petitioners' accountants, Mr. Whittington and                      
             Ms. Ruble, followed the practice that they had established               
             in prior years.  Ms. Ruble contacted Ms. Cates in March or               
             early April 1990, and they discussed the changes to                      
             petitioners' taxable income for 1988 that were necessary to              
             estimate petitioners' taxable income for 1989.  During this              
             discussion, Ms. Ruble reviewed petitioners' 1988 return and              
             Ms. Cates reviewed petitioners' books, records, and other                
             tax information.  They identified a number of changes that               
             were necessary in estimating petitioners' 1989 taxable                   
             income.  These included subtracting the profit reported for              
             1988 from the cattle feeding business to reflect the fact                
             that Mr. Harrison had disposed of his investment in the                  
             business during 1988, subtracting the income reported from               
             the Houston firm to reflect Mr. Harrison's withdrawal from               
             the firm in 1988, adding payments attributable to the sale               
             of Mr. Harrison's interest in the Houston firm, as offset                
             by a carryover of capital losses from the termination of                 
             Cooper's Alley Restaurant, and subtracting the expenses                  
             incurred by Mr. Harrison in connection with his law firm in              
             Corpus Christi.                                                          








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