Padgett Coventry Price - Page 37

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          income and withheld information from her return preparer.                   
          Accordingly, petitioner’s good faith reliance defense is without            
          merit.  Bender v. Commissioner, 256 F.2d 771, 774-775 (7th Cir.             
          1958), affg. T.C. Memo. 1957-121; see Weis v. Commissioner, 94              
          T.C. 473, 487 (1990).                                                       
                    3.   Petitioner’s Alleged Disease/Disability                      
               Petitioner claims that since 1964 she has suffered from a              
          severe learning disability that made her incapable of “dealing              
          with the simplest of bookkeeping, banking, and/or financial                 
          data.”  Petitioner referred to her alleged disease as dyscalculia           
          and disnumeria.  Dyscalculia is a disease that relates to                   
          difficulty in performing simple mathematical problems.  PDR                 
          Medical Dictionary 550 (2d ed. 2000).                                       
               Petitioner introduced no expert testimony regarding her                
          alleged medical condition.  Apart from her self-serving                     
          testimony, which was not credible, one witness testified that               
          mathematics was not petitioner’s strong point and that the                  
          witness observed petitioner use a calculator when she did                   
          mathematics.                                                                
               Petitioner’s records from the University of California                 
          Riverside and Western State University College of Law contain no            
          record of petitioner’s suffering from any kind of learning                  
          disability.  As a practicing attorney, petitioner regularly                 
          computed child support figures for clients.  According to her               






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