- 2 - 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 sectionPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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