Thomas N. Coccia - Page 6

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               2.  Schedules C                                                        
               Petitioner attached Schedules C to the March return and to             
          the "amended return" he submitted to respondent.  The activities            
          reported therein included security brokerage services and the               
          operation of a newsstand.                                                   
                    a.  Security Brokerage Services                                   
               Respondent received a Form 1099, Miscellaneous Income, from            
          RBA Associates, Inc., reporting that petitioner received                    
          nonemployee compensation of $1,024 in 2000.  On the March return,           
          petitioner attached a Schedule C for the principal business of              
          "Retail Stand" reporting income of $1,024, costs of goods sold of           
          $1,024, and expenses of $2,900.  Attached to his "amended return"           
          is a Schedule C-EZ, Net Profit From Business, for the principal             
          business of "Security" reflecting gross receipts of $1,024 and              
          total expenses of $1,024.                                                   
               Petitioner does not have any records pertaining to this                
          transaction other than the Form 1099.  He did not report any                
          self-employment tax liability on the March return he submitted to           
          respondent or on the "amended return" he submitted at trial.                
               b.  Newsstand                                                          
               In 2000, petitioner attempted to open a newsstand in South             
          Philadelphia.  Petitioner does not have any records pertaining to           
          his expenses for the newsstand.                                             

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