Michael and Patricia Vetrano - Page 4




                                        - 4 -                                         
                  During the years in issue, 1991 through 1993,                       
             petitioner received payroll checks from BMAP CORP, also                  
             known as Bill Murray Auto Parts (referred to herein in as                
             BMAP) and another business, Anastasi Brothers Corp., that                
             are reflected on Forms W-2, Wage and Tax Statements, issued              
             to petitioner.  The Forms W-2 report wages in the following              
             amounts:                                                                 
                                     1991           1992       1993                   
             BMAP                    $2,744.00    $14,560    $14,000                  
             Anastasi Bros. Corp.    5,860.80      -0–       -0–                      
                                     8,604.80     14,560     14,000                   

             The above amounts are reported on Mr. Vetrano’s separate                 
             returns for 1991 and 1992 and petitioners’ joint return for              
             1993.                                                                    
                  During the years in issue, petitioner’s income was                  
             derived principally from his automobile parts business.                  
             He did little or no work as a bricklayer.  Petitioner                    
             received the following nonpayroll payments from BMAP and                 
             four other entities:                                                     















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