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Atmore, Escambia County, Alabama, when they filed their
petitions.
Petitioners have been married since December 18, 1967, and
have filed joint Federal income tax returns for all years,
including their 1997 tax year at issue in this case. Charles R.
Godwin (petitioner) is an attorney who has been engaged in the
practice of law since May 1974. Petitioner worked in his law
practice 12 hours per day, 6 days per week throughout 1997 and
1998. Petitioner’s first job as an attorney was as an estate and
gift tax attorney with the Internal Revenue Service (IRS).
During the year in issue, petitioner practiced law at his office
in Atmore, Alabama. Petitioner is admitted to practice before
this Court and is the attorney of record in these cases. Linda
S. Godwin (Mrs. Godwin) is a teacher with the Alabama public
school system.
Issue 1. Additions to Tax Under Sections 6654(a) and 6651(a)(1)
and (2)
FINDINGS OF FACT
Sometime during April-May 1997, petitioner received a legal
fee of “a little over a million dollars” (the $1 million fee) for
representing a client in a personal injury case. The $1 million
fee was the largest fee petitioner had ever received. The $1
million fee caused petitioners’ taxable income to be higher for
1997 than it has ever been before or since for tax years covered
by the record in this case.
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