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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
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