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tournament program for 2000. We disagree. Whether Omaha State
Bank was mentioned in the Special Friends event program is not
relevant to whether Special Friends could process credit card
payments.
Petitioners contend that Hughs admitted that the letter that
she received from Special Friends was a forgery. We disagree.
Hughs did not admit that the letter she received from Special
Friends was forged.
These circumstances leave us no alternative but to conclude
that petitioner altered (or caused to be altered) the letter from
Special Friends by adding a paragraph stating that he had
purchased an advertisement in the program for $7,500 payable with
two charges to his Visa card, and misrepresented that the altered
letter was a correct copy.
b. Deducting the Same Item Several Times
Claiming deductions for the same item more than once on the
same return may be a badge of fraud. See Edwards v.
Commissioner, T.C. Memo. 1995-77.
Petitioners contend: (1) That they did not deduct the same
item in several places on their 2000 return; (2) if they did,
they did so because of errors in their tax preparation software;
and (3) it is not a badge of fraud to deduct the same item two or
more times. We disagree.
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