Anthony J. Kadillak - Page 8

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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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