-3- 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, thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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