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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 a
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