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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.
Background
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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