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remaining liability due was $963,597. Petitioner failed to remit
the full amount of tax due with his return.
Respondent assessed a tax liability of $1,099,388 (IRS
reduced total tax by $60 foreign tax credit) for 2000 and mailed
petitioner a notice of balance due on June 4, 2001. Petitioner
has not fully paid the balance.
Petitioner filed his 2001 Federal income tax return on or
about April 20, 2002, which was also prepared by a certified
public accountant and accepted by the IRS.4 The return reported
wages of $204,722, capital loss of $865, dividend income of
$3,279, and, after itemized deductions of $292,525, zero taxable
income. The 2001 return also reported zero tax and zero AMT,
with an overpayment of $12,720. The return did not report gain
or loss from the forfeiture of the 6,667 nonvested shares granted
under option No. 117 for regular tax or AMT purposes. Respondent
assessed a tax liability of zero for 2001 on June 10, 2002.
2. Amended Federal Income Tax Returns for 2000 and 2001
On March 25, 2003, 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
4 The return was originally sent to the IRS on approximately
Mar. 30, 2002, and returned to petitioner on approximately Apr.
17, 2002, because petitioner’s signature was missing.
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