- 10 - 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 bePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011