Hector Prowse - Page 12

                                       - 11 -                                         
          Court’s finding that petitioner fraudulently claimed Schedule A             
          itemized deductions on his 2001 Federal income tax return.                  
               While the case in Prowse v. Commissioner, supra, was                   
          pending, respondent issued the statutory notice of deficiency,              
          upon which this case is based, determining that petitioner was              
          not entitled to any of the claimed itemized Schedules A                     
          deductions on his 2002 and 2003 tax returns.                                
               Following this Court’s opinion involving petitioner’s 2001             
          tax year and the finding of fraud under section 6663 for that               
          year, supra note 2, respondent moved in this case to impose the             
          section 6663 fraud penalty against petitioner for the 2002 and              
          2003 tax years.  In the alternative, respondent asserted an                 
          accuracy-related penalty for both years.                                    
          Schedule A Deductions                                                       
               For the 2 years at issue, petitioner claimed on his income             
          tax returns deductions on Schedules A.  For the year 2002, the              
          deductions claimed were:                                                    

               Medical and dental expenses                     $ 2,119                
          Taxes                                               416                     
               Charitable gifts                                  1,910                
               Job expenses and other miscellaneous expenses    12,077                
               Total                                         $16,522                  

          For the year 2003, the claimed deductions were:                             









Page:  Previous  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  Next

Last modified: May 25, 2011