-3-
additional checks. Again, the signatures on the checks are
illegible.
Respondent, concluding that the above documentation was
inadequate, disallowed all $36,182 of the deductions claimed on
Schedule A, Itemized Deductions, of petitioner’s 2003 Federal
income tax return ($23,885 in home mortgage interest, $8,673 in
state income tax, $363 in contributions, and $3,261 in
miscellaneous expenses).
Petitioner protested respondent’s audit adjustments to
respondent’s Appeals Office but did not explain to respondent’s
Appeals Office the confusing checks and signatures that
petitioner had provided to respondent.
On November 28, 2005, respondent determined a deficiency of
$6,077 in petitioner’s 2003 Federal income taxes. The deficiency
was based on a disallowance by respondent of the $36,182 claimed
Schedule A deductions.
On January 25, 2006, petitioner filed a petition regarding
respondent’s November 28, 2005, notice of deficiency. In the
petition, petitioner claimed that the documentation petitioner
submitted to respondent during the audit adequately substantiated
the deductions respondent had disallowed.
On March 7, 2006, respondent filed an answer in which
respondent argued that the documentation petitioner submitted to
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