- 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 NextLast modified: May 25, 2011