Linda D. Fason - Page 1

                                 T.C. Memo. 1999-405                                  

                               UNITED STATES TAX COURT                                

                            LINDA D. FASON, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 12308-98.                Filed December 14, 1999.           

                    R disallowed deductions claimed on P’s 1994 income tax            
               return and determined the civil fraud penalty pursuant to              
               sec. 6663, I.R.C.  In substantiation of these deductions, P            
               offered two documents which evidence at trial indicated were           
               not legitimate.                                                        
                    Held: On the facts, P failed to establish her                     
               entitlement to the deductions claimed and is therefore                 
               liable for the deficiency determined by respondent.                    
                    Held, further, P is liable for the sec. 6663, I.R.C.,             
               civil fraud penalty.                                                   

               Linda D. Fason, pro se.                                                
               Ric D. Hulshoff, for respondent.                                       

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