Charles R. Godwin et al. - Page 9

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               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 to              








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