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Since graduating from law school, petitioner has practiced law
in California. At the time of trial, he worked out of his home and
was affiliated with several Santa Monica law firms, working in the
area of financial mergers and acquisitions.
1986 Federal Income Tax Return
On January 30, 1990, petitioner filed his 1986 Federal income
tax return, electing to have a $1,177 overpayment for such year
applied to his 1987 tax return.
1987 Tax Year
Petitioner made estimated tax payments of $2,500 each on April
15, June 15, and September 15, 1987. On April 15, 1988, petitioner
(1) requested an extension of time (to August 15, 1988) to file his
1987 tax return, and (2) remitted $20,000 therewith.1
Petitioner did not file a 1987 return. Accordingly, on
February 22, 1993, the Internal Revenue Service (IRS) filed a
substitute 1987 return for petitioner based on payor information
documents. On October 30, 1995, the IRS made a tax assessment for
the year 1987 in the amount of $12,751. The IRS applied the $1,177
overpayment from 1986 to petitioner's 1987 tax liability.
1 The Internal Revenue Service credited $4,201 to
petitioner's then wife's account and $15,799 to petitioner's
account.
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