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practice by overstating business expenses. Petitioner’s
understatements of net income due to overstated business expenses
were $20,339.19 for taxable year 1989, $39,398.18 for taxable
year 1990, $19,066.73 for taxable year 1991, $23,269.61 for
taxable year 1992, and $16,555.64 for taxable year 1993.
Petitioners’ original 1989 Federal income tax return
reported a tax of $18,473.30. In their final amended 1989
Federal income tax return, petitioners reported that their total
tax liability was $53,270.62 of which $51,913.76 had been paid
and $1,356.86 was still due. Petitioners’ original 1990 Federal
income tax return reported a tax of $16,937.90. In their final
amended 1990 Federal income tax return, petitioners reported that
their total tax liability was $52,594.07 of which $47,564.02 had
been paid and $5,030.05 was still due. Petitioners’ original
1991 Federal income tax return reported a tax due of $8,607.61.
In their final amended 1991 Federal income tax return,
petitioners reported that their total tax liability was
$26,959.52 of which $20,513.52 had been paid and $6,446 was still
due. Petitioners’ original 1992 Federal income tax return
reported a tax due of $11,895.81. In their final amended 1992
return, petitioners reported that their total tax liability was
$42,715.22 of which $36,715.80 had been paid and $5,999.42 was
still due. Petitioners’ original 1993 Federal income tax return
reported a tax due of $14,210.40. In their final amended 1993
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