William M. Hawkins and Laura C. Hawkins - Page 3

                                        - 2 -                                         
               Respondent determined deficiencies in petitioners’ Federal             
          income taxes, additions to tax, and penalties as follows:                   
                                        Additions to Tax    Penalties                 
               Year      Deficiency     Sec. 6651(a)(1)     Sec. 6662                 
               1992        $25,952           $5,929           $5,190                  
               1993          5,914              870            1,183                  
               1994         12,751            2,597            2,550                  
               The issues for decision for each year in issue are:  (1)               
          Whether petitioners underreported income; (2) whether petitioners           
          are entitled to depreciation deductions greater than those                  
          respondent allowed; (3) whether petitioners are entitled to a               
          deduction for charitable contributions; (4) whether petitioners             
          had reasonable cause for their failure to file a timely Federal             
          income tax return; and (5) whether the underpayment of tax                  
          required to be shown on petitioners’ Federal income tax return is           
          due to negligence.                                                          
          Background                                                                  
               Some of the facts have been stipulated and are so found.               
          Petitioners are husband and wife.  They filed an untimely Federal           
          income tax return for each year in issue.  At the time the                  
          petition was filed, they resided in Indianapolis, Indiana.                  
               William M. Hawkins (petitioner) is an attorney.  He has                
          practiced law since 1971 and did so as a sole practitioner during           
          the years in issue.  Petitioners’ Federal income tax return for             
          each year in issue includes a Schedule C, Profit or Loss From               
          Business, on which income and expenses attributable to                      





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011