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A. Petitioner’s Income Tax Return for 1999
On October 17, 2000, petitioner timely filed a Form 1040,
U.S. Individual Income Tax Return, for the taxable year 1999.
Petitioner attached, inter alia, to the return a Schedule C,
Profit or Loss From Business. On Schedule C, petitioner
identified his business name as “Alfonsos of Hollywood” and his
principal business or profession as “other leather and allied
product mfg”. Petitioner reported net profit from his business
on Schedule C of $4,254. On the return, petitioner reported
adjusted gross income (AGI) of $3,953, zero taxable income, and
self-employment tax of $601. He also claimed an EIC of $1,590
and a refund of $989.
On May 28, 2002, petitioner filed an amended return for the
taxable year 1999. On the amended return, petitioner reported
AGI of $29,487, taxable income of $14,887, self-employment tax of
$4,483, and total tax of $5,714. He also claimed a child tax
credit of $1,000 and an EIC of $233. He did not remit payment
with the amended return.
On the basis of petitioner’s 1999 amended return, respondent
assessed additional tax plus statutory interest and an addition
to tax for failure to timely pay under section 6651(a)(2).2
2 On Oct. 28 and Nov. 11, 2002, respondent partially abated
interest for reasons unexplained in the record.
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