- 2 - Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the issues for decision are: (1) Whether petitioners had unreported income from Latin Investment Corporation in 1988; (2) whether petitioners had unreported income from L&L Construction Company in 1988; (3) whether petitioners are entitled to home mortgage and personal interest deductions for 1988 and 1989 in an amount greater than allowed by respondent; (4) whether petitioners are entitled to certain business deductions claimed on their Schedule C for 1988; (5) whether petitioners are liable for increased self-employment tax in 1988; (6) whether petitioners are liable for the addition to tax and penalty for negligence for 1988 and 1989, respectively; and (7) whether petitioners are liable for the substantial understatement addition to tax for 1988. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. At the time the petition was filed, petitioners resided in Vienna, Virginia. Fernando Leonzo (petitioner) was president and an owner of the Latin Investment Corporation (LIC). Petitioner received a salary from LIC. In 1988, petitioner was involved with startingPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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