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states that petitioners' total income tax liability for
1990 is $2,560, that they had Federal income tax withheld
for the year of $2,560, that they had a balance due of
zero. The Form W-2, Wage and Tax Statement, for
petitioner's wife for 1990 lists $2,560 in Federal income
tax withheld.
In August 1991, petitioners' accountants filed,
on their behalf, a Form 2688 requesting an additional
extension of time to file petitioners' 1990 return.
The Form 2688 states that petitioners' accountant was
overworked and was unable to complete petitioners' return.
On or about October 18, 1991, petitioners filed a
joint individual income tax return for 1990 on Form 1040.
They paid $124,186 with the return. This amount consists
of total tax of $124,103, less the Federal income tax
withheld of $2,560, plus a penalty for underpayment of
estimated tax of $2,643.
On the Schedule C, Profit or Loss From Business, filed
with the return, petitioners reported gross income of
$50,331, total expenses of $61,267, and a loss of $10,936
from Mr. Harrison's law practice in Corpus Christi.
Petitioners also reported on Schedule E, Supplemental
Income and Loss, a loss of $113,338 from W.O. Harrison,
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