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4. Whether Phillip Vazzana and Estate of Yvonne Vazzana
correctly reported a capital gain they recognized on the sale of
a house. We hold that they did not.
5. Whether Joseph M. Valenza and Mildred Valenza are
entitled to deduct $2,485 of business expenses. We hold that
they are not.
6. Whether petitioners are liable for additions to tax for
fraud. We hold that they are to the extent provided below.
7. Whether petitioners are liable for additions to tax for
negligence. We hold that they are to the extent provided below.
8. Whether petitioners are liable for additions to tax for
substantial understatements of income tax. We hold that they are
to the extent provided below.
9. Whether assessment and collection of the deficiencies
and additions to tax are barred by expiration of the statutory
period of limitations. We hold that they are not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time they filed their respective petitions, Phillip Vazzana
resided in Lockport, Illinois, and Joseph and Mildred Valenza
resided in Burr Ridge, Illinois.
During the years in issue, Messrs. Vazzana and Valenza each
owned a 50-percent interest in V&V, an Illinois general
partnership located in Chicago, Illinois. V&V constructed and
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