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During the subject year, Mr. Huff was an attorney
specializing in personal injury work in the State of California.1
He practiced law through his sole proprietorship. His practice
during 1997 paid wages of $92,000 to his wife and withheld from
those wages Federal income taxes of $16,327. These withholdings
were the only Federal income tax payments petitioners made during
1997.
Respondent’s records show that petitioners filed their 1991
Federal income tax return untimely on June 5, 1994, that they
filed their 1992 Federal income tax return untimely on October
20, 1993, that they filed their 1993 Federal income tax return
untimely on February 9, 1995, that they filed their 1994 Federal
income tax return untimely on October 15, 1995, that they filed
their 1995 Federal income tax return untimely on June 11, 1997,
that they filed their 1999 Federal income tax return untimely on
September 13, 2001, and that they filed their 2000 Federal income
tax return untimely on September 17, 2001.2 Respondent’s records
show that petitioners filed their 1996 Federal income tax return
timely on July 31, 1997, after requesting and receiving an
extension of the due date for the return to August 15, 1997, and
1 As of May 5, 2003, the date of trial, Mr. Huff had been
practicing law for 14 years.
2 Petitioners had received extensions until Aug. 15, 1995,
and Aug. 15, 2001, to file their returns for 1994 and 2000,
respectively.
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