Carol A. Black and William R. Adams - Page 2

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          for additions to tax under section 6651(a) that had been assessed           
          as a result of petitioners’ late-filed returns.  Unless otherwise           
          indicated, all section references are to the Internal Revenue               
          Code in effect for the years in issue.                                      
                                  FINDINGS OF FACT                                    
               Petitioners were both lawyers who resided in Philadelphia,             
          Pennsylvania, when they filed the petition in this case.                    
          Petitioner William R. Adams, Jr. (Adams), operated his own law              
          firm from 1982.  For 1991 through 1994, Adams incurred tax                  
          liabilities of $163,583.49, including additions to tax for late             
          filing, late payment, and failure to pay estimated tax.  These              
          liabilities were paid in September 1996.                                    
               Adams kept his own business records and entered information            
          from them into a computer software program to generate printouts            
          that he provided to his accountant to prepare tax returns.  Adams           
          kept the records at his place of business.                                  
               Petitioners filed joint Federal income tax returns, Forms              
          1040, U.S. Individual Income Tax Return, for 1995, 1996, and 1997           
          between 2 and 12 months after extended filing dates.  Petitioners           
          did not fully pay the tax shown as due on the returns filed for             
          1995, 1996, and 1997.  On Schedules C, Profit or Loss From                  
          Business, for Adams’s law practice, attached to the Forms 1040,             
          petitioners reported gross receipts of $435,206 for 1995,                   
          $345,550 for 1996, and $416,364 for 1997.                                   

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