- 9 -
On April 10, 1999, Mr. Krasner presented to petitioner
completed joint Form 1040, U.S. Individual Income Tax Return, for
taxable year 1998 (1998 joint return), and reviewed at least the
first three pages of that completed return with her. Those pages
showed, inter alia, wages of $242,248, “Business income” of
$55,000 reflected in Schedule C, Profit or Loss From Business, a
loss of $4,483 from “Rental real estate, royalties, partnerships,
S corporations, trusts, etc.” reflected in Schedule E, Supplemen-
tal Income and Loss, Federal income tax (tax) of $66,361, total
tax payments of $28,037, and tax due of $38,324.11
In reviewing the 1998 joint return with petitioner on April
10, 1999, Mr. Krasner informed her that they owed $38,324 of tax
for 1998 and that they needed to make arrangements with the
Internal Revenue Service (IRS) to set up an installment plan to
pay that tax liability just as they had previously done with
respect to their joint tax liability for 1992.12 Mr. Krasner
11Around the end of 1998, Schiffman Hughes Brown, P.C.,
certified public accountants (Schiffman Hughes Brown), who
represented Mr. Krasner and petitioner on, inter alia, their tax
matters informed Mr. Krasner that insufficient withholding had
been made for the first three quarters of 1998 with respect to
their projected tax liability for that year.
12For taxable year 1992, petitioner and Mr. Krasner filed a
joint tax return (1992 joint return) that showed tax due, the
amount of which is not disclosed by the record and which they did
not pay when they filed that return. During 1994, Mr. Krasner
and the IRS agreed to an installment plan about which petitioner
was aware and under which petitioner and he agreed to make
monthly payments of their liability for taxable year 1992. At a
time not disclosed by the record, Mr. Krasner received an inheri-
(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