Fernando and Maria Leonzo - Page 2

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          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               After concessions, the issues for decision are:  (1) Whether           
          petitioners had unreported income from Latin Investment                     
          Corporation in 1988; (2) whether petitioners had unreported                 
          income from L&L Construction Company in 1988; (3) whether                   
          petitioners are entitled to home mortgage and personal interest             
          deductions for 1988 and 1989 in an amount greater than allowed by           
          respondent; (4) whether petitioners are entitled to certain                 
          business deductions claimed on their Schedule C for 1988;                   
          (5) whether petitioners are liable for increased self-employment            
          tax in 1988; (6) whether petitioners are liable for the addition            
          to tax and penalty for negligence for 1988 and 1989,                        
          respectively; and (7) whether petitioners are liable for the                
          substantial understatement addition to tax for 1988.                        
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.  At the           
          time the petition was filed, petitioners resided in Vienna,                 
          Virginia.                                                                   
               Fernando Leonzo (petitioner) was president and an owner of             
          the Latin Investment Corporation (LIC).  Petitioner received a              
          salary from LIC.  In 1988, petitioner was involved with starting            




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