David E. Caruso, Jr. and Barbara Caruso - Page 3

                                        - 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 section              






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

Last modified: May 25, 2011