Charles R. Godwin et al. - Page 4

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          Atmore, Escambia County, Alabama, when they filed their                     
               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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