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(11) Whether petitioner Francesca Tabbi qualifies as an
innocent spouse under section 6013(e). We hold that she does
not.
Respondent concedes that petitioners are not liable for the
addition to tax for fraud for 1987, and that petitioner Francesca
Tabbi is not liable for the addition to tax for fraud for 1988
and 1989.
References to petitioner husband are to Bruno Tabbi.
References to petitioner wife are to Francesca (or Frances P.)
Tabbi. Section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
1. Petitioners
Petitioners resided in Clinton Township, Michigan, when they
filed the petition.
Petitioner wife worked as a secretary for her father,
Salvatore LoChirco (LoChirco), at Oliver Homes, Inc. (Oliver
Homes), from 1978 to 1988. She did not work in petitioner
husband's office and was not involved in his real estate
business.
Petitioners had two children born before 1988. Petitioners'
son Antonino was born in September 1988 with severe heart
problems that led to his death in August 1990. Petitioner wife
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