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taxable years 1987 and 1988). That decision provided in perti-
nent part as follows:
Pursuant to agreement of the parties in this case,
it is
ORDERED and DECIDED: That there are deficiencies
in income tax due from the petitioners for the taxable
years 1987 and 1988 in the amounts of $3,827 and
$10,463, respectively;
That there is an addition to the tax due from the
petitioners under the provisions of I.R.C. � 6661 for
the taxable years 1987 and 1988 in the amounts of $930
and $2,158, respectively; and
That there are no additions to the tax due from
the petitioners under the provisions of I.R.C. ��
6653(a)(1)(A), 6653(a)(1)(B) and 6653(a)(1) for the
taxable years 1987 and 1988.
Joseph N. Iezzi (Mr. Iezzi), a certified public accountant,
prepared Form 1040 that petitioner and Mr. Monsour signed and
jointly filed for each of their taxable years 1989 (1989 joint
return), 1990 (original 1990 joint return), 1991 (1991 joint
return), 1992 (1992 joint return), and 1993 (1993 joint return).4
4Petitioner and Mr. Monsour filed a joint tax return (joint
return) for each of their taxable years 1989, 1990, 1991, 1992,
and 1993 on the dates indicated:
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