- 10 - Petitioner knew that he would owe tax as a result of the distribution of profits from Mercer, but petitioners failed to make estimated tax payments and paid only $500 when they filed their return. Nevertheless, petitioners argue they had reasonable cause for their failure to timely pay their full tax liability because they made reasonable efforts to conserve sufficient assets in marketable form to satisfy their tax liability but were nevertheless unable to pay the tax when it became due. Petitioners assert they invested the profits received from Mercer with Merrill Lynch “into stocks like Intel and high tech stocks and things that were safe”. However, petitioners assert that “Merrill Lynch lost it”, leaving petitioners unable to satisfy their tax obligations. Petitioner testified that he believed he was making a conservative investment and he “thought it was the same thing as a bank.” While petitioners provided Ms. Russo with bank statements to support their contention that they were unable to pay their outstanding tax liability, they did not provide Ms. Russo with information regarding their investment with Merrill Lynch. Other than petitioner’s testimony, there is no evidence in the record concerning petitioners’ investment with Merrill Lynch, or that such an investment was even made. Other than stating they invested in “stocks like Intel and high tech stocks”, petitioners have not specifically identified what stocks they invested in.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007