- 3 - work. Sal Parziale was employed as a supervisor with Joseph Williams Homes Construction Co. (JWH), a subsidiary of the Italian Brothers Construction Co. (IBC). Sal Parziale’s brother, Joseph Parziale, was president of both IBC and JWH. The projects involved the restoration of houses damaged by flood or fire for which payment was made to JWH by insurance companies. Petitioner was hired by Sal Parziale to work on three projects. He worked on the “Roach” project, a house damaged by fire, the “Penny” project, a water damaged trailer, and the “Wise” project on which he did some painting. Petitioner was paid for his work after the insurance companies paid JWH. Petitioners’ 1997 Federal Income tax return was received and date stamped by the Commissioner on September 4, 1998. Petitioners did not report any income from JWH and the Parziale brothers. Sal Parziale sent to petitioner and the Commissioner Form 1099-MISC, Miscellaneous Income, reporting nonemployee compensation paid to petitioner of $27,429 for 1997. The notice of deficiency determined an increase in petitioners’ income of $27,429, which was the amount reflected on Form 1099-MISC. The petition states that “Barry Mangels worked for John Salvatore Parziale and made $6,000 not $27,429.” At trial, petitioner conceded that he received $11,471 in income in 1997 from Sal Parziale by way of checks.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011