Marcelo E. Ferrada and Gloria D. Ferrada - Page 3

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               Respondent determined for 1998 a deficiency in petitioners'            
          Federal income tax of $10,338 and an addition to tax under                  
          section 6651(a)(1) of $2,434.50.  The issues for decision are:              
          (1) Whether petitioners are entitled to deductions on Schedule C,           
          Profit or Loss From Business, in excess of those allowed by                 
          respondent; and (2) whether petitioners are subject to an                   
          addition to tax under section 6651(a)(1) for failure to file                
          timely their 1998 Federal income tax return.                                
                                     Background                                       
               The stipulation of facts and the exhibits received into                
          evidence are incorporated herein by reference.  Petitioners                 
          resided in Houston, Texas, at the time the petition was filed.              
               During the year in issue, Mr. Ferrada was employed as a                
          contractor in the aviation industry.  Petitioners also operated a           
          food stand.                                                                 
          1.   Mr. Ferrada's Employment                                               
               In October 1997 petitioners and their son lived in Tucson,             
          Arizona.  At that time, Mr. Ferrada was hired by Global Technical           
          Services (GTS), an Air Force subcontractor, for a position of               
          indefinite length in Lake Charles, Louisiana.  In December 1997             
          GTS was replaced as a subcontractor by Air Mate.  Mr. Ferrada               
          continued to work in the same position for Air Mate.  In February           
          1998 Mr. Ferrada began working for Hi-Tec Associates, Inc. (Hi-             
          Tec).  He continued working on the same project as before but in            






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