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Respondent also determined the following deficiency and
penalty with respect to petitioners’ Federal income tax for
1993:
Year Deficiency Fraud Penalty
1993 $32,114 $24,086
The issues for decision are: (1) Whether Mr. Vetrano
(referred to herein as petitioner) earned unreported net
income in 1991, 1992, and 1993 from his business of dealing
in used automobile parts; (2) whether petitioner is subject
to self-employment tax with respect to the unreported
income from his automobile parts business; (3) whether
returns at issue are subject to the fraud penalty under
section 6663 and, if so, whether some part of the
underpayment for 1993 is due to the fraud of Mrs. Patricia
Vetrano; and (4) whether Mrs. Patricia Vetrano is eligible
for relief as an innocent spouse under section 6015 or
former section 6013. Unless stated otherwise, all section
references in this opinion are to the Internal Revenue Code
as in effect during the years in issue.
FINDINGS OF FACT
Petitioners are husband and wife. They filed separate
returns for 1991 and 1992 and a joint return for 1993.
Mrs. Vetrano’s separate returns for 1991 and 1992 are not
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