Natalia Ravelo Escandon - Page 7




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         indicates that respondent prepared an SFR on January 14, 2005.               
         The record also includes a Form 13496, IRC Section 6020(b)                   
         Certification, pertaining to petitioner’s 2003 tax year and dated            
         February 11, 2005.  The Court has also admitted a copy of the SFR            
         which indicates that it was filed on January 14, 2005, and which             
         reports the adjustments contained in the notice of deficiency.               
         Statements from FAWI and Mimi’s reflecting payments to petitioner            
         in 2003 of $208 and $11,210, respectively are attached to the                
         SFR.                                                                         
              Section 6020(b) provides:                                               
              SEC. 6020(b).  Execution of Return by Secretary.--                      
                    (1)  Authority of Secretary to execute return.--If                
               any person fails to make any return required by any                    
               internal revenue law or regulation made thereunder at                  
               the time prescribed therefor, or makes, willfully or                   
               otherwise, a false or fraudulent return, the Secretary                 
               shall make such return from his own knowledge and from                 
               such information as he can obtain through testimony or                 
               otherwise.                                                             
                    (2)  Status of returns.--Any return so made and                   
               subscribed by the Secretary shall be prima facie good                  
               and sufficient for all legal purposes.                                 
              The record reveals that respondent generated an SFR for                 
         petitioner’s 2003 tax year based on statements provided by Mimi’s            
         and FAWI.  Petitioner concedes that she received the income                  
         reported in the SFR and that she has not paid the tax shown on               
         the SFR.  The SFR complies with section 6020(b).  The SFR                    
         therefore constitutes a return for the purposes of the section               
         6651(a)(2) addition to tax.  Sec. 6651(g)(2).  Accordingly,                  






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