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(2) Whether Michael J. Friscia (Michael Friscia) had
unreported income of $35,915 for 1995. We hold that he had
unreported income of $4,196.
(3) Whether the Friscias and Michael Friscia are liable for
self-employment tax on the unreported income for 1994 and 1995,
respectively. We hold that they are.
(4) Whether the Friscias and Michael Friscia are liable for
the accuracy-related penalty under section 6662(a) for the 1994
and 1995 taxable years. We hold that they are.
(5) Whether Michael Friscia is liable for the addition to
tax for failure to file timely under section 6651(a)(1). We hold
that he is.
(6) Whether deductions and costs of goods sold claimed by
Friscia Construction, Inc. (Friscia Construction), in excess of
$108,160 have been substantiated and are allowable. We hold that
for the taxable year ended June 30, 1995, Friscia Construction
had gross receipts of $260,921 and allowable deductions and costs
of goods sold in the total amount of $229,796.
(7) Whether Friscia Construction is liable for the
accuracy-related penalty under section 6662(a). We hold that it
is.
(8) Whether Friscia Construction is liable for the addition
to tax for failure to file timely under section 6651(a)(1). We
hold that it is.
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