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of a total tax of $38,702, less Federal income tax withheld
of $2,374, plus a penalty for the underpayment of estimated
tax of $2,438, and a penalty and interest for late payment
in the aggregate amount of $3,149.
On the Schedule C, Profit or Loss From Business, filed
with their return, petitioners reported a net loss of
$208,542 from Mr. Harrison's law practice in Corpus
Christi. They reported gross income of $28 and total
expenses of $208,570 from this business, including
depreciation of $3,319. Included among the assets on which
depreciation is claimed are expenditures during 1989 for
furniture in the aggregate amount of $17,982 and leasehold
improvements of $64,199. On a Form 6252, Installment Sale
Income, filed with their return, petitioners reported that
they had received $552,218 from the sale of Mr. Harrison's
interest in the Houston firm, of which 94.77 percent or
$523,337 was long-term capital gain from an installment
sale.
Petitioners' Joint Return for 1990
In April 1991, petitioners' accountant filed, on their
behalf, a Form 4868, requesting an automatic extension of
time to file petitioners' 1990 return. The Form 4868
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