Linda D. Fason - Page 10

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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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