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explanations of her behavior. The medical receipt and
petitioner’s first letter to respondent refer to payment in the
form of a cashier’s check. Petitioner’s second letter to
respondent, in contrast, states that payment was made in cash.
The documentary evidence she offered and her own written
statements are therefore directly contradictory.
Similarly, petitioner offered a contribution statement from
Trinity Baptist Church which designates her by name as a donor.
Then, in her third letter to respondent, petitioner attempts to
explain the church’s lack of information regarding her gifts by
writing that her contributions were anonymous. However, if her
contributions were truly anonymous, so that her giving would not
be reflected in the church records, the church would not have
been able to issue a personal contribution statement. Again,
petitioner’s explanations are contradictory and implausible.
Furthermore, prolonging the examination of her return for
several years with false and conflicting communications can
hardly be deemed cooperation with tax authorities.
Based on these circumstances, we hold that petitioner is
liable for the section 6663 civil fraud penalty, and we need not
reach the alternative question of whether petitioner would be
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Last modified: May 25, 2011