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Joseph A. DelVecchio and Carol DelVecchio, pro se.
Leonard T. Provenzale, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: By notice of deficiency dated January 20,
1994, respondent determined deficiencies in, and additions to,
petitioners’ 1987 and 1988 Federal income taxes as follows:
Joseph DelVecchio:
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6653(b)(1)(A) 6653(b)(1) 6653(b)(1)(B) 6661
1987 $29,400 $22,050 -- 1 $7,350
1988 16,699 -- $12,524 -- 4,175
150% of the interest payable under sec. 6601.
Carol DelVecchio:
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6653(a)(1) 6661
1987 $29,400 $1,470 1 -- $7,350
1988 16,699 –- -- $835 4,175
150% of the interest payable under sec. 6601.
Following the trial in this case, respondent moved to amend
the answer to conform the pleadings to the proof, to take account
of amended tax returns received into evidence (which show items
of income in excess of respondent’s previous adjustments). We
granted that motion and, as amended, the answer now avers
deficiencies in, and additions to, petitioners’ Federal income
taxes for 1987 and 1988 as follows:
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