Edward C. Rosa - Page 3

                                        - 2 -                                         
               Respondent determined a deficiency of $3,104 in petitioner’s           
          Federal income tax for 2000 and an addition to tax under section            
          6651(a)(1) of $109.  After petitioner’s concession of unreported            
          income of $10,881, the issues for decision are whether                      
          petitioner:  (1) Is entitled to itemized deductions of $5,704,              
          (2) is entitled to deduct business expenses of $8,882, and (3) is           
          liable for the addition to tax for failure to file timely a                 
          Federal income tax return.                                                  
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits received in evidence              
          are incorporated herein by reference.  At the time the petition             
          was filed, petitioner resided in Vega Alta, Puerto Rico.                    
               Petitioner filed on April 28, 2001, a Federal income tax               
          return for 2000.  The return failed to report $10,881 of                    
          nonemployee income earned by petitioner in 2000 from “J&S Floor             
          Covering” (J&S).  After the statutory notice of deficiency in               
          this case was issued, petitioner submitted to respondent a Form             
          1040X, Amended U.S. Individual Income Tax Return, reporting the             
          $10,881 of nonemployee income omitted from his tax return.  The             
          amended return also reported for the first time on Schedule A,              
          Itemized Deductions, itemized deductions of $5,704 and on                   
          Schedule C, Profit or Loss From Business, business expense                  
          deductions of $8,882.                                                       

Page:  Previous  1  2  3  4  5  6  7  Next

Last modified: May 25, 2011