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The issues raised by the notice of deficiency are (1) whether
petitioners had unreported income from various sources and (2)
whether petitioners are entitled to a loss claimed on Schedule C,
Profit or Loss From Business. Petitioners resided in Bridgeport,
Connecticut, at the time the petition was filed.
We have combined to a great extent our findings of fact and
conclusions of law because of the confused state of the record.
This case was calendared for trial on March 5, 2001, in
Hartford, Connecticut, and was recalled on March 7, 2001. At the
recall, Michelle B. O’Connor, Esq. (Ms. O’Connor), from the
Quinnipiac University School of Law Tax Clinic entered an
appearance on behalf of petitioners, and a stipulation of facts
was executed by Ms. O’Connor and petitioner Zinovy V. Reytblatt
(hereafter petitioner). The stipulation of facts provided, inter
alia, that with respect to the 1996 tax return (1) petitioner
Natalia B. Romalis-Reytblatt received nonemployee compensation of
$1,200 that was not reported; (2) petitioners erroneously
reported an additional $1,200 in wage income; (3) petitioner
received nonemployee compensation of $1,300 that was not
reported; (4) petitioners received dividend income of $62 and
interest income of $334 that were not reported; (5) petitioners
received $57 from an annuity that was not reported; (6)
petitioners were not entitled to a Schedule C loss of $11,833;
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