Phillip Vazzana and Estate of Yvonne Vazzana, Deceased, Phllip Vazzana, Executor - Page 5

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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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