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corresponding deductions for, the following expenditures and
losses: $8,611 for medical expenses, $7,214 for charitable
contributions, $4,659 for casualty losses, and $12,656 for
employee and miscellaneous expenses.
During an audit of her 1994 return, petitioner provided two
documents for purposes of substantiating her expenses. The first
was a receipt on letterhead of Richard Hill, Sr., M.D. The
receipt designates Richard Harden, petitioner’s son, as “patient”
and bears $8,611.37 both as the amount of “charges” and as the
amount “paid”. A handwritten annotation on the receipt reads:
“Pd by L. Fason cashier chk”.
The second item provided by petitioner for substantiation
purposes was a document on letterhead of Trinity Baptist Church
entitled “1994 Contribution Statement”. It states that Linda
Fason contributed $7,214 during 1994.
On October 10, 1996, respondent sent petitioner a
information document request asking for a copy of the cashier’s
check used to pay Dr. Richard Hill. Petitioner responded in a
letter dated October 15, 1996: “Regarding your letter to me
(copy enclosed) about a copy of cashiers check paid to Dr.’s bill
the check had no copy.”
Respondent then sent a second information document request
on April 16, 1997, again soliciting a copy of the cashier’s check
or, if such was unavailable, verification of the method (i.e.,
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