- 5 - (2) whether respondent has satisfied his burden of proving by clear and convincing evidence that petitioner is liable for the civil fraud penalty under section 6663(a). FINDINGS OF FACT Some of the facts have been stipulated and are so found. We incorporate the stipulated facts into our findings by this reference. Petitioner resided in Flushing, New York, when his petition in this case was filed. Petitioner’s 2001 Return During 2001, petitioner was employed by Keyspan Engineering Associates and by Cosentini Associates. Petitioner filed a timely Federal income tax return for 2001 on which he reported the income he had earned from his employment during 2001. On Schedule A, Itemized Deductions, of his 2001 return, petitioner claimed itemized deductions of $31,449.06, and on Schedule C, Profit or Loss From Business, petitioner claimed a bad debt deduction of $20,000 and a deduction for legal expenses of $1,300. The Schedule A itemized deductions that petitioner claimed on his 2001 return consisted of the following:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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