Michael C. Hollen and Joan L. Hollen - Page 5




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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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