Linda D. Fason - Page 7

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          erroneous.  With respect to the medical expenses, the only                  
          substantiation offered by petitioner is the purported receipt               
          from Dr. Richard Hill.  Dr. Hill, however, testified that the               
          document was not a receipt prepared by his office, and we find              
          his testimony to be credible.  As to the charitable                         
          contributions, the sole item offered in substantiation, the 1994            
          Contribution Statement, is likewise shown by a credible witness             
          to be lacking in legitimacy.  Ms. Debra Hannah, the financial               
          secretary of Trinity Baptist Church, stated that the contribution           
          records of the church contained no reference to a gift from                 
               Regarding the casualty losses and business and miscellaneous           
          deductions, no substantiation other than the lists set forth in             
          petitioner’s return has been presented.  Hence, because                     
          demonstrably fraudulent evidence will not validate a deduction,             
          nor, of course, will the complete absence of evidence, the                  
          presumption of correctness afforded to respondent’s deficiency              
          determination is not rebutted.  Petitioner is therefore liable              
          for the deficiency determined by respondent.                                
          Civil Fraud Penalty                                                         
               Section 6663(a) authorizes the imposition of a civil fraud             
          penalty and reads as follows:  “If any part of any underpayment             
          of tax required to be shown on a return is due to fraud, there              
          shall be added to the tax an amount equal to 75 percent of the              

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