Omar Urbina Pineda - Page 4

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          A.  Petitioner’s Income Tax Return for 1999                                 
               On October 17, 2000, petitioner timely filed a Form 1040,              
          U.S. Individual Income Tax Return, for the taxable year 1999.               
          Petitioner attached, inter alia, to the return a Schedule C,                
          Profit or Loss From Business.  On Schedule C, petitioner                    
          identified his business name as “Alfonsos of Hollywood” and his             
          principal business or profession as “other leather and allied               
          product mfg”.  Petitioner reported net profit from his business             
          on Schedule C of $4,254.  On the return, petitioner reported                
          adjusted gross income (AGI) of $3,953, zero taxable income, and             
          self-employment tax of $601.  He also claimed an EIC of $1,590              
          and a refund of $989.                                                       
               On May 28, 2002, petitioner filed an amended return for the            
          taxable year 1999.  On the amended return, petitioner reported              
          AGI of $29,487, taxable income of $14,887, self-employment tax of           
          $4,483, and total tax of $5,714.  He also claimed a child tax               
          credit of $1,000 and an EIC of $233.  He did not remit payment              
          with the amended return.                                                    
               On the basis of petitioner’s 1999 amended return, respondent           
          assessed additional tax plus statutory interest and an addition             
          to tax for failure to timely pay under section 6651(a)(2).2                 




               2  On Oct. 28 and Nov. 11, 2002, respondent partially abated           
          interest for reasons unexplained in the record.                             





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