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transportation ($720), classes ($2,300), and one-half of meals
and entertainment expenses totaling $650 ($325). Petitioner
attached to his 2001 return a copy of a letter from the New York
City Public Schools confirming that petitioner had paid $2,300
for classes in asbestos and paint lead abatement. The letter
purported to be signed by Robert Pardi and was dated July 1,
2001. Unfortunately, Mr. Pardi died on December 23, 1999, and
could not possibly have written the July 1, 2001, letter. In
addition, no such classes were offered by the New York City
Public Schools during 2001.2 With respect to the balance of the
employee business expenses, petitioner was not required by either
of his employers to incur travel or client entertainment expenses
during 2001. Even if petitioner had incurred such expenses, each
of his 2001 employers had reimbursement policies that entitled
their employees to obtain reimbursement for any required business
expenses.
To document the Schedule C legal expenses of $1,300 that he
claimed on his 2001 return, petitioner attached to his 2001
return a letter dated May 15, 2001, from Michael E. Greenblatt,
an attorney allegedly employed by Nixon, Hargrave, Devans & Doyle
LLP. However, Mr. Greenblatt never worked for Nixon Hargrave,
2Similar documents were submitted to substantiate charitable
contributions, medical expenses, and employee business expenses
claimed on petitioner’s 2000 return. At least some of those
documents also appear to have been falsified.
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