Bruno and Francesca Tabbi - Page 51

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          to pay many of petitioners' personal, living expenses.  Also,               
          given petitioner wife's modest income in these years, she must              
          have used petitioner husband's unreported income to buy the                 
          Tanglewood home for $175,000 in 1987, and to build the Alden home           
          for $160,000 in 1989.                                                       
               We believe that petitioner wife fully benefited from the               
          omitted income.  We believe that she fully shared in the tax                
          savings from the omitted income and that the understatements let            
          her maintain a standard of living that she would not have enjoyed           
          otherwise.  See Scarafile v. Commissioner, T.C. Memo. 1991-512.             
               To reflect the foregoing,                                              

          Decision will be entered                                                    
          under Rule 155.                                                             























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