Michael and Patricia Vetrano - Page 2




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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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