Michael F. Lambaiso and Judy D. Lambaiso - Page 3




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          the revenue agent erred in computing the amount of sales of                 
          alcoholic beverages sold at discounted prices during "happy hours".         
               The other remaining issues are (1) whether petitioners are             
          entitled to deduct 1991 unreimbursed automobile expenses allegedly          
          incurred in connection with Classic Pub's operation, and (2)                
          whether petitioners are liable for the section 6662(a) accuracy-            
          related penalty for 1991, 1992, and 1993.                                   
               All section references are to the Internal Revenue Code in             
          effect for the years under consideration.  All Rule references are          
          to the Tax Court Rules of Practice and Procedure.  All dollar               
          amounts are rounded.                                                        
                                  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.                                                   
          Background                                                                  
               At the time Michael F. and Jody D. Lambaiso (petitioners),             
          husband and wife, filed their petition, they resided in Virginia            
          Beach, Virginia. They filed joint Federal income tax returns for            
          all years in issue.                                                         
          Classic Pub                                                                 
               Classic Pub, Inc. is a Virginia corporation.  In 1990, it              
          elected S corporation status for Federal tax purposes;                      







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