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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