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SDC liquidated and distributed the property to Messrs. Vazzana
and Valenza. During 1988 and 1989, they each received unreported
gross receipts from the property of $32,162 and $8,730,
respectively.
In 1988, Mr. and Mrs. Vazzana sold a house they had
constructed. On their joint 1988 Federal income tax return, they
reported the $348,000 realized on the sale, a cost basis of
$333,158, and a capital gain of $14,842.
The Vazzanas filed their 1988 and 1989 Federal income tax
returns on April 17, 1989, and April 9, 1990, respectively, and
reported adjusted gross income of $31,719 for 1988 and $32,115
for 1989. The Valenzas filed their 1988 and 1989 Federal income
tax returns on April 14, 1989, and April 9, 1990, respectively,
and reported adjusted gross income of $18,397 for 1988 and
$38,197 for 1989. On April 12, 1995, petitioners executed Forms
872, extending the time for assessment of their 1988 taxes to
October 31, 1995. On October 27, 1995, respondent issued notices
of deficiency to petitioners.
OPINION
I. Unreported V&V Gross Receipts
Petitioners have conceded that they underreported V&V's
gross receipts by $70,935 for 1988 and $69,494 for 1989.
Respondent, however, contends that V&V received additional
unreported gross receipts of $80,915 for 1988 and $43,656 for
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