Bruno and Francesca Tabbi - Page 15

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          Petitioners lived in the Tanglewood home in 1987 and 1988.                  
          Petitioners spent $15,000 to improve that home while petitioner             
          wife owned it.  On August 2, 1988, petitioner wife sold it for              
          $237,000.  Petitioner wife had sales expenses of $561.  Her cost            
          basis in the house was $210,691.                                            
               On February 22, 1989, petitioner wife bought a lot at 41741            
          Alden, Clinton Township, Michigan, for $35,000.  Canta built a              
          residence on this lot in 1989.  Petitioner wife bought the                  
          residence on October 12, 1989, for $160,000.                                
          9.   Petitioners' Returns                                                   
               H & R Block prepared petitioners' 1987 and 1988 returns.               
          Petitioner husband gave H & R Block various documents to prepare            
          those returns.  For the 1988 Schedule C, he gave H & R Block only           
          his real estate commission receipts totaling $15,480 as shown on            
          a Form 1099.  He did not give them records of commission checks             
          that he cashed before depositing, records of corporate payment of           
          petitioners' personal expenses, or records of commissions                   
          petitioner husband received that were payable to another entity.            
               Petitioners did not review the returns before signing them.            
          They did not claim all of their exemptions for 1987.                        
               Gerald Carnago, of Carnago, Neddermeyer & Bringard, prepared           
          petitioners' 1989 return.  Petitioners filed their returns for              
          1987 on April 25, 1988, for 1988 on September 5, 1989, and for              
          1989 on October 23, 1990.                                                   






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