Robert C. and Patricia C. Humphrey - Page 7

                                        - 7 -                                         
          12/15/97 NSO     864       4,415        50,814      46,399                  
          10/21/98 NSO  30,000       104,532      1,764,375   1,659,843               
          B.   2000 Federal Income Tax Returns                                        
               Petitioner filed his 2000 Federal income tax return on April           
          16, 2001, which was prepared by Henry, Held and Associates, P.C.            
          The return reported wages of $20,243,699, taxable interest of               
          $5,521, ordinary dividends of $190,346, capital gains of                    
          $3,587,913, miscellaneous income of $16,000, and, after a self-             
          employment tax deduction of $215 and itemized deductions of                 
          $45,905, taxable income of $23,997,359.  The return reported                
          regular tax of $8,772,392, AMT of zero, and a self-employment tax           
          of $429.  After applying a foreign tax credit of $312 and total             
          payments of $6,067,851, the remaining unpaid income tax liability           
          was $2,704,658.  Respondent assessed the income tax liability on            
          May 28, 2001.  Petitioner has not fully paid the balance.                   
               On March 25, 2002, relying on the advice of Brian G.                   
          Isaacson, a tax attorney, petitioner filed a Form 1040X, Amended            
          U.S. Individual Income Tax Return, amending his 2000 Federal                
          income tax return (2000 amended return) with a Form 8275,                   
          Disclosure Statement.4  The 2000 amended return reported wage               

               4 The amended return prepared by Mr. Isaacson included a               
          Form 8275, which contained Mr. Isaacson’s tax opinion letter to             
          petitioner.  To avoid certain penalties, Form 8275 is used by               
          taxpayers to disclose items or positions that are not otherwise             
          adequately disclosed on a tax return.  The form is filed to avoid           
          the portions of the accuracy-related penalty due to disregard of            
                                                             (continued...)           





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011