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Phillip Vazzana and Estate of Yvonne Vazzana, docket No. 914-96
Additions to Tax
Year Deficiency Sec. 6653(a) Sec. 6653(b)(1) Sec. 6661 Sec. 6663(a)
1988 $69,781 $1,786 $25,550 $17,445 --
1989 190,002 -- -- -- $14,251
Joseph M. Valenza and Mildred Valenza, docket No. 915-96
Additions to Tax
Year Deficiency Sec. 6653(a) Sec. 6653(b)(1) Sec. 6661 Sec. 6663(a)
1988 $28,383 $112 $19,609 $7,096 --
1989 20,941 -- -- -- $15,706
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 as follows:
1. The extent to which petitioners underreported the gross
receipts of Valenza & Vazzana Construction Co. (V&V). We hold
that they underreported such receipts by $121,289 for 1988 and
$101,029 for 1989.
2. Whether petitioners have substantiated certain V&V
expenditures. We hold that they have to the extent provided
below.
3. Whether petitioners are each entitled to a depreciation
deduction relating to their rental property. We hold that they
are not.
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