Bruno and Francesca Tabbi - Page 2

                                        - 2 -                                         
          Additions to Tax                                                            
          Sec.          Sec.          Sec.      Sec.                                  
          Year    Deficiency  6651(a)(1)  6653(a)(1)(A) 6653(a)(1)(B)  6661           
          1987    $108,314       $79          $232            1       $27,078         
          1988      66,102        --         3,3052          --        16,526         
          1989      36,411     8,695           --            --          --           
          Sec.              Sec.        Sec.      Sec.     Sec.                       
          Year    6653(b)(1)(A)    6653(b)(1)(B)   6653(b)    6662     6663           
          1987     $77,762               3            --       --       --            
          1988        --                --         $49,576     --       --            
          1989        --                --            --     $2,304   $19,012         
               1 Fifty percent of the interest due on $4,632.                         
               2 Sec. 6653(a)(1) for 1988.                                            
               3 Fifty percent of the interest due on $103,682.                       
               After concessions, the issues for decision are:                        
               (1) Whether petitioners had unreported income of $47,068               
          for 1987, $87,711 for 1988, and $30,475 for 1989.  We hold that             
          they did, except as discussed below.                                        
               (2) Whether petitioners' unreported income is subject to               
          self-employment tax for 1987, 1988, and 1989.  We hold that it              
          is, except as conceded by respondent.                                       
               (3) Whether petitioners had unreported income of $25,518               
          from the sale of their residence in 1988.  We hold that they did.           
               (4) Whether petitioners' gains and losses from the sale of             
          real property in 1987, 1988, and 1989 were capital or ordinary.             
          We hold that they were ordinary.                                            
               (5) Whether petitioners had unreported capital gains of                
          $2,500 from the sale of their interest in Bagnasco-Tabbi Funeral            
          Home.  We hold that they did.                                               







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