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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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