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$5,900 cost for surgery performed at St. Luke’s/Roosevelt
Hospital on March 13, 2001, had been paid, and a receipt dated
May 25, 2001, from Harvey S. Pallen, DDS, confirming treatment of
petitioner on various dates in May 2001 for a total cost of $900.
Each of the above-described documents was falsified, and some, if
not all, of the signatures shown on the documents were forged.
None of the documents substantiated any of petitioner’s claimed
medical expenses for 2001.
The charitable gifts claimed on the Schedule A consisted of
an alleged cash gift to a church and a noncash contribution. The
noncash contribution consisted of claimed donations of property
to the Salvation Army during 2001. To document the contribution,
petitioner attached receipt No. 414, dated December 13, 2001,
purportedly from the Salvation Army, that listed 12 categories of
property, assigned a value to each category, and listed the total
contribution as $1,640. The receipt showed that the contribution
was received by “Juanita Rusell” on December 13, 2001. The
receipt was falsified and does not substantiate petitioner’s
claimed noncash contribution for 2001. Petitioner did not attach
to his 2001 return any substantiation of his alleged cash gift to
the church, and he did not substantiate the gift during the
examination of his return.
The employee business expenses of $16,293 consisted of
vehicle expenses ($12,948), parking fees, tolls, and
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