Hector Prowse - Page 10

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          Notice of Deficiency                                                        
               In the notice of deficiency, respondent disallowed                     
          petitioner’s Schedule C bad debt deduction of $20,000 and his               
          Schedule C legal expense deduction of $1,300.  As a result of               
          these adjustments, respondent made a computational adjustment               
          reducing petitioner’s itemized deductions by $2,195 but did not             
          otherwise disallow the itemized deductions petitioner had claimed           
          on Schedule A.  Respondent did not assert that petitioner was               
          liable for any addition to tax or penalty.                                  
          Amendment to Answer                                                         
               After respondent uncovered evidence that petitioner had                
          overstated his Schedule A itemized deductions and had falsified             
          documentation to substantiate his Schedules A and C deductions,             
          respondent amended his answer to the amended petition to assert             
          an additional deficiency of $5,784.14 (thereby increasing the               
          total claimed deficiency for 2001 to $10,980.143) resulting from            
          the complete disallowance of petitioner’s itemized deductions for           
          lack of substantiation.  Respondent also asserted for the first             
          time that petitioner was liable for the fraud penalty pursuant to           
          section 6663(a).                                                            




               3In his motion, respondent conceded a computational mistake            
          in calculating the original deficiency.  The corrected original             
          deficiency is $5,196.                                                       





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