-2-
Federal income taxes from petitioner Joseph A. DelVecchio of
approximately $189,137.62 for 1987 and $177,448.78 for 1988, and
from petitioner Carol DelVecchio of approximately $129,600.27 for
1987 and $110,905.53 for 1988.2 The case is before the Court on
respondent’s motion for summary judgment under Rule 121.
Petitioners filed a response.
We shall grant respondent’s motion for summary judgment.
Background
Petitioners filed Federal income tax returns for 1987 and
1988. Upon audit, all parties signed Form 872, Consent to Extend
the Time to Assess Tax, allowing respondent until December 31,
1992, to assess “The amount of any Federal Income tax due on any
returns made by or for the above taxpayer(s)” for 1987 and 1988.
A notice of deficiency was issued for those years on January 20,
1994, and trial was held in this Court on April 21, 1999, in
Miami, Florida. An opinion was issued, holding for respondent.
See DelVecchio v. Commissioner, T.C. Memo. 2001-130.3 Decision
was entered for respondent on August 9, 2001, and assessment was
made on November 13, 2001. The decision was affirmed by the
Court of Appeals for the Eleventh Circuit on May 29, 2002.
2 We say “approximately” as these amounts were computed
before the present proceeding and have since increased on account
of interest.
3 In part, the Court decided that petitioners are liable for
certain deficiencies and that Joseph DelVecchio is liable for
additions to tax for fraud.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011