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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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