Ester A. D'Avilar - Page 3

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          reviewable by any other court, and this opinion should not be               
          cited as authority.                                                         
               Respondent determined a $3,026 deficiency in petitioner’s              
          2000 Federal income tax.  Petitioner has conceded the correctness           
          of the adjustments that give rise to the deficiency.  The dispute           
          between the parties focuses on petitioner’s entitlement to                  
          deductions not claimed on her original return.                              
               The issues for decision are:  (1) Whether petitioner is                
          entitled to various itemized and business expense deductions                
          shown on an amended return not processed by respondent (the                 
          unprocessed amended return); (2) whether respondent may claim an            
          increased deficiency based upon income reported on a Schedule C             
          included with the unprocessed amended return; and (3) whether               
          respondent may now assert a section 6662(a) accuracy-related                
          penalty based upon petitioner’s failure to keep records to                  
          substantiate deductions claimed on the unprocessed amended                  
          return.                                                                     
                                    Background                                        
               Some of the facts have been stipulated and are so found.  At           
          the time the petition was filed, petitioner resided in Brooklyn,            
          New York.                                                                   
               During the year in issue, petitioner:  (1) Was employed by             
          the City of New York and earned wages totaling $23,646.39,                  
          evidenced by the issuance of a Form W-2, Wage and Tax Statement,            






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