- 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