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LARO, Judge: These cases were consolidated for purposes of
trial, briefing, and opinion. Respondent determined deficiencies
in, additions to, and penalties on petitioners’ Federal income
tax as follows:
Michael J. and Michelle R. Friscia, docket No. 19973-98:
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1994 $41,904 $8,380.80
Michael J. Friscia, docket No. 19975-98:
Addition to Tax and Penalty
Year Deficiency Sec. 6651(a) Sec. 6662(a)
1995 $21,350 $2,146.10 $4,270
Friscia Construction, Inc., docket No. 19874-98:
Fiscal Year Addition to Tax and Penalty
Ended Deficiency Sec. 6651(a) Sec. 6662(a)
6/30/95 $84,814 $21,203.50 $16,963.80
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue, and Rule
references are to the Tax Court Rules of Practice and Procedure.
Hereinafter, all dollar amounts are rounded to the nearest
dollar.
After concessions, the issues for decision are:
(1) Whether Michael and Michelle Friscia (the Friscias) had
unreported income of $82,586 for 1994. We hold that they had
unreported income of $28,215.
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