Michael and Patricia Vetrano - Page 3




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             at issue in this proceeding.  At the time they filed the                 
             instant petition, petitioners resided in Sicklerville, New               
             Jersey.                                                                  
                  Petitioner is a bricklayer.  His returns for 1986 and               
             1987 report wages of $15,119 and $10,123, respectively,                  
             that appear to be from employment as a bricklayer.  Circa                
             1984, he entered into the business of dealing in used                    
             automobile parts.  Petitioner’s 1986 and 1987 income tax                 
             returns include Schedules C, Profit or (Loss) From Business              
             Or Profession, that report income and deductions from an                 
             automobile parts sales business operating under the name B               
             & D Auto Parts.  The Schedules C report the following                    
             income and deductions:                                                   

             B & D Auto Parts                     1986           1987                 
                  Gross receipts or sales       $103,329       $109,029               
                  Cost of goods sold            -91,429        -96,453                
                  Gross profit                  11,900         12,576                 
                  Deductions                                                          
                  Car and truck expenses        3,315          3,540                  
                  Office expense                22             25                     
                  Utilities and telephone       297            289                    
                  Total deductions              3,634          3,854                  
                  Net profit or (loss)          8,266          8,722                  

             Petitioners’ returns for 1986 and 1987 were prepared by a                
             public accountant, Mr. Dennis F. Judge.                                  






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