- 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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