Bruno and Francesca Tabbi - Page 50

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          either directly or indirectly, from the unreported income.                  
          Hayman v. Commissioner, 992 F.2d 1256, 1262 (2d Cir. 1993), affg.           
          T.C. Memo. 1992-228; Belk v. Commissioner, 93 T.C. 434, 440                 
          (1989); Purcell v. Commissioner, 86 T.C. at 242; H. Rept. 98-432            
          (part 2), at 1501, 1502 (1984); sec. 1.6013-5(b), Income Tax                
          Regs.  Normal support is determined by the circumstances of the             
          taxpayers.  Sanders v. United States, 509 F.2d at 168; Estate of            
          Krock v. Commissioner, 93 T.C. 672, 678 (1989); Flynn v.                    
          Commissioner, 93 T.C. 355, 367 (1989).                                      
               Petitioners argue that petitioner wife did not benefit from            
          the substantial understatement of income by petitioner husband              
          or receive substantial amounts from petitioner husband in the               
          years at issue.  Petitioners point out that petitioner wife owned           
          the home in which petitioners lived and she owned a home on                 
          LaGrange which she sold in 1987.  Her net cash proceeds were                
          $23,562, $14,848 of which she deposited in her household account.           
          She also received $64,482 from the sale of her home in 1988,                
          which she deposited in her own account.                                     
               Petitioner wife benefited from the understatements on                  
          petitioners' 1987, 1988, and 1989 returns.  Petitioner wife had             
          wages of $15,500 in 1987, $10,200 in 1988, and none in 1989, and            
          therefore depended on petitioner husband for her support.  In               
          1987 and 1988 petitioner husband deposited funds in her bank                
          accounts which she used to pay household expenses.  In 1989,                
          petitioner husband used the Premiere and Canta corporate accounts           




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