Linda D. Fason - Page 3

                                        - 3 -                                         
          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.,              

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  Next

Last modified: May 25, 2011