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$10,0004 and assumed the sellers' liability to Mr. and Mrs.
Lentz. The sellers executed a grant deed conveying title to Mr.
and Mrs. Pou in October 1988, and the partnership dissolved
thereafter.
On or about March 15, 1989, the partnership filed its 1988
partnership return in which it recognized gain of $631,507 from
the sale of the ranch. The partnership also issued to
petitioner, in his individual name, a Schedule K-1, Partner’s
Share of Income, Credits, Deductions, Etc., showing his
distributive share of partnership income, which included a one-
third share of the gain from the sale of the ranch. The
partnership’s return was prepared by the partnership’s
accountant, David Evans, and filed as its final return.
In April 1989, petitioners filed Form 4868, Application for
Automatic Extension of Time to File U.S. Individual Income Tax
Return, requesting an extension of time to file their 1988
Federal income tax return. The Form 4868 was prepared by
petitioners’ accountant, Louis Fettkether. It reported an
estimated tax liability for 1988 of $80,000, which petitioners
paid with the extension request. Petitioners' estimated tax
4The check was made payable to petitioners personally and
not to the partnership or the P.C. However, the payment was
treated as a partnership distribution on the partnership’s 1988
return and on the Schedule K-1, Partner’s Share of Income,
Credits, Deductions, Etc., issued to petitioner.
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