Andrea Pappas - Page 5

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               Subsequently, in November 1999, petitioner filed an amended            
          income tax return, Form 1040X, Amended U.S. Individual Income Tax           
          Return, for the 1993 taxable year.  The amount of tax shown on              
          the amended return was $29,203.                                             
               On December 6, 1999, respondent processed petitioner’s                 
          amended tax return and assessed the $29,203 of income tax due, as           
          reported by petitioner on the Form 1040X.                                   
               After processing the amended return, respondent determined             
          that petitioner was liable for an addition to tax of $6,570.68,             
          pursuant to section 6651(a)(1), for failure to file her 1993                
          income tax return within the time prescribed by law.  The                   
          addition to tax was computed based on the $29,203 of tax shown on           
          the amended tax return.  On December 6, 1999, respondent assessed           
          the addition to tax of $6,570.68.                                           
               Petitioner asserts that on January 31, 2000, she filed a               
          second amended tax return, Form 1040X, indicating that the tax              
          reported on the first amended return was erroneously computed.              
          Petitioner claims that on the second amended return she reported            
          no tax liability for the 1993 taxable year.  Petitioner further             
          asserts that respondent rejected the second amended return as               
          untimely.                                                                   
          Discussion                                                                  
               This Court is a court of limited jurisdiction, and we may              
          exercise our jurisdiction only to the extent authorized by                  






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