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proceed with collection of petitioners’ Federal income tax
liability for the 1999 tax year.
Some of the facts were stipulated. Those facts, with the
exhibits annexed thereto, are so found and made part hereof.
Petitioners’ legal residence at the time the petition was filed
was New Orleans, Louisiana.
Petitioners live and work in Louisiana. Mr. Caruso is a
practicing attorney who specializes in personal injury law.
During the year at issue, Mr. Caruso was a salaried employee at a
small local firm. He worked at this firm until June 2002, when
he left that firm and joined another local firm. Mrs. Caruso is
also an attorney licensed in California but did not practice law
during the year at issue. Instead, she was employed part time as
a paralegal for several New Orleans firms.
Petitioners did not file their 1999 joint Federal tax return
until March 17, 2003. They had previously filed for, and been
granted, an extension to file until October 15, 2000.
Petitioners did not file for additional extensions after October
15, 2000, nor did they make any estimated tax payments. On their
1999 return, petitioners reported a tax liability of $91,200 and
withholding credits of $8,677. Petitioners did not remit payment
for the remaining $82,523 balance due.
On May 12, 2003, petitioners were assessed a section
6651(a)(1) addition to tax in the amount of $18,635, a section
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