- 9 - necessary to promptly pay the taxes as it had done in years past. This is primarily because the 1997 law practice income was extraordinarily high, followed by comparatively much lower income in 1998. 5. We are now negotiating a loan at various lending institutions for the purpose of paying the tax. On December 21, 1998, MSC received petitioners’ 1997 tax return. On their 1997 return, petitioners reported net profit of $1,458,835.02 from petitioner’s law practice. On their 1997 return, petitioners deducted $526,833 for casualty losses resulting from Hurricane Danny, the 1997 earthquakes, and Hurricane Georges. On their 1997 return, petitioners reported cash gifts to charity of $285,010, substantially exceeding their total charitable contributions for the 3 immediately preceding years. On their 1997 return, petitioners reported total tax liability of $291,340.82 for 1997. Petitioners made a $10,000 payment by check with their 1997 return, leaving unpaid the remaining $281,340.82 tax liability shown thereon. Petitioners, in the cover letter dated December 14, 1998, with which they filed their 1997 return, requested an extension of time to pay the tax for a reasonable time from the date of filing the return, for reasons substantially similar to those asserted in their letters of August 14 and November 16, 1998. Respondent assessed the unpaid tax liability reported on petitioners’ 1997 return and accrued interest and additions toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011