Anthony J. Marzullo and Mary P. Marzullo - Page 3

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          disallowed itemized deductions.  They contest:  (1) Mr. Marzullo's          
          liability for the fraud addition to tax for 1986; (2) Mrs.                  
          Marzullo's liability for tax, claiming that Mrs. Marzullo is an             
          innocent spouse; (3) the self-employment tax; and (4) Mrs.                  
          Marzullo's liability for the fraud addition to tax. Thus, the               
          issues for decision are:  (1) Whether Mrs. Marzullo is entitled to          
          relief as an innocent spouse pursuant to section 6013(e); (2)               
          whether Mrs. Marzullo is liable for self-employment tax relating to         
          income from MPM subsequent to August 31, 1987; and (3) whether Mr.          
          Marzullo is liable for the fraud addition to tax for 1986, and              
          whether Mrs. Marzullo is liable for the fraud additions to tax for          
          1986, 1987, and 1988.                                                       
               All section references are to the Internal Revenue Code as in          
          effect for the years under consideration.  All Rule references are          
          to the Tax Court Rules of Practice and Procedure.  Petitioner               
          Anthony J. Marzullo is herein referred to as Mr. Marzullo and               
          petitioner Mary P. Marzullo as Mrs. Marzullo.  Together they are            
          referred to as petitioners.                                                 
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  The          
          stipulation of facts and the attached exhibits are incorporated             
          herein by this reference.                                                   
               Petitioners, husband and wife, resided in Glen Arm, Maryland,          
          at the time they filed their petition.  Petitioners timely filed            
          joint Federal income tax returns for 1986, 1987, and 1988, the              




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