Michael B. Butler and Jean Butler - Page 8




                                        - 8 -                                         
               Petitioners filed a joint Federal income tax return for                
          1988.  By September 16, 1991, they owed $109,580.82 on their 1988           
          income tax liabilities.  Notices of Federal Tax Lien concerning             
          that joint liability were filed during the fall of 1991.  On                
          October 4, 1991, petitioners' 1989 Federal income tax return was            
          filed on their behalf approximately 1 year late.  They had filed            
          and received two extensions of time in which to file their 1989             
          return.  No payment was made with the filing of the 1989 return,            
          and, on November 4, 1991, the IRS assessed penalties for a                  
          failure to pay estimated tax and for late filing.  During the               
          winter and spring of 1992, the IRS recorded Notices of Federal              
          Tax Lien against petitioners relating to their 1989 return.                 
          Petitioners' 1990 joint Federal income tax return was filed on              
          their behalf on December 17, 1991, 8 months late.  On December              
          17, 1991, penalties for the late filing and for failure to pay              
          estimated tax were assessed against petitioners.  During the                
          Spring of 1992, the IRS recorded Notices of Federal Tax Lien                
          concerning petitioners' 1990 joint tax liability.                           
               In the notice of deficiency sent to petitioners in the                 
          instant case, respondent determined that petitioners failed to              
          include flowthrough income from BGE in the amounts of $79,380 and           
          $18 on their 1992 joint Federal income tax return.  Petitioners             
          concede that the flowthrough from BGE for petitioner's husband's            
          share of the net settlement proceeds ($79,380) received by BGE              






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011