Thomas N. Coccia - Page 4

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               Petitioner, a Philadelphia police officer, failed to file              
          timely a Federal income tax return for taxable year 2000.                   
          Respondent determined petitioner's income on the basis of                   
          information returns submitted to respondent by third party                  
          payors.  Respondent also determined that petitioner is liable for           
          the above-listed additions to tax.                                          
               On March 19, 2004, after respondent issued petitioner a                
          statutory notice of deficiency, petitioner submitted a tax return           
          for 2000 (March return).  Respondent has not processed the March            
          return, and no tax has been assessed as a result of petitioner's            
          submission of the March return.                                             
               After the petition was filed, respondent filed an answer               
          conceding that petitioner is not liable for an addition to tax              
          under section 6651(a)(2) and asserting an increase in the                   
          addition to tax under section 6651(a)(1) of $157.35.                        
               At trial, petitioner submitted an additional tax return he             
          referred to as an "amended return" for taxable year 2000.                   
          A.   Petitioner's Income for the 2000 Taxable Year                          
               1.  Wages                                                              
               In 2000, petitioner received wages of $6,275 from Society              
          Hill Towers.  He also received wages of $66,935 from the City of            
          Philadelphia.  Federal income tax of $10,289 was withheld from              
          petitioner's wages.                                                         

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