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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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