Barry John and Deborah Lee Houston Mangels - Page 4




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          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.                                    








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