George A. and Hilda Quintero - Page 3

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               Respondent determined an $8,780 deficiency in, and a $1,756            
          penalty under section 6662(a) with respect to petitioners’ 1997             
          Federal income tax.  The Court must decide:  (1) The amount of              
          compensation George A. Quintero earned and received from AAA                
          Transmissions Service Center of North Miami, Florida (AAA),                 
          during 1997; (2) whether such compensation constitutes self-                
          employment income subject to the tax imposed by section 1401;               
          and (3) whether the underpayment of tax required to be shown on             
          petitioners’ 1997 Federal income tax return is a substantial                
          understatement of income tax.                                               
               Some of the facts have been stipulated and are so found.               
          Petitioners are husband and wife.  They filed a timely joint 1997           
          Federal income tax return.  At the time the amended petition was            
          filed, petitioners resided in Pompano Beach, Florida.  References           
          to petitioner are to George A. Quintero.                                    
               During 1997, petitioner was a student at the Ft. Lauderdale            
          campus of Keiser College.  From the beginning of the year until             
          sometime in December, he was also employed as a “trainee-helper”            
          by AAA, an automobile transmission repair shop.                             
               Petitioner was not a certified mechanic during 1997.  His              
          duties at AAA included the removal and replacement of automobile            
          transmissions, but he did not repair or rebuild transmissions.              
          When at work he wore a uniform provided by AAA, he used tools               

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