Hector Prowse - Page 7

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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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