- 3 - Joseph DelVecchio: Additions to Tax Sec. Sec. Sec. Sec. Year Deficiency 6653(b)(1)(A) 6653(b)(1) 6653(b)(1)(B) 6661 1987 $30,789 $23,092 -- 1 $7,697 1988 29,282 -- $21,961 -- 7,321 150% 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 $30,789 $1,539 1 -- $7,697 1988 29,282 –- -- $1,464 7,321 150% of the interest payable under sec. 6601. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The principal issues remaining for decision are petitioners’ claims that they are entitled to net operating loss deductions for the years in issue and the additions to tax. FINDINGS OF FACT Residence Petitioners resided in Stuart, Florida, at the time the petition was filed. Monterey Glass and Mirror Distributors Petitioner Joseph DelVecchio (Joseph) is a glazier. During the years in issue, Joseph sold glass to both wholesale and retail customers. Joseph carried on his business as aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011