William S. Fairey, Jr., and Susan R. Fairey - Page 27

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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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