- 7 -
that the 1992 return would be timely filed. On the 1992 return,
the Cheshires reported that they had received a $199,771 retirement
distribution and that $56,150 of that amount constituted taxable
income. In addition, they reported $477 in interest income, as
well as a $12,349 loss on their Schedule C, Profit or Loss From
Business.
In August 1994, petitioner received a letter from the Internal
Revenue Service (IRS) stating that it had not received the
Cheshires’ 1992 return. In searching for a copy of the 1992
return, petitioner discovered in a desk drawer the original 1992
return as well as a check for the amount of tax shown to be owing
($23.86). Petitioner immediately contacted Mr. Mican; he advised
her to file the 1992 return and enclose payment for the tax
liability reflected on the return as soon as possible. Petitioner
filed the 1992 return along with the remittance on August 15, 1994.
In early October 1994, petitioner received notification from
the IRS that $8,502 in estimated tax payments claimed on the
Cheshires’ 1992 return had not been paid. Despite Mr. Cheshire’s
reassurance that he had made the estimated tax payments, petitioner
discovered that the payments in fact had not been made. Upon the
advice of Mr. Mican, petitioner paid the estimated tax using
borrowed funds.
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