Hector Prowse - Page 13

                                       - 12 -                                         
               Medical and dental expenses                        $958                
               Charitable gifts                                  1,443                
               Job expenses and other miscellaneous expenses    18,700                
               Total                                         $21,101                  

               In the notice of deficiency, respondent disallowed some of             
          these expenses and, by motion, asserted that petitioner was                 
          liable for fraud under section 6663(a) with respect to some of              
          the claimed deductions.                                                     
               Section 213(a) allows a taxpayer who itemizes his or her               
          deductions to deduct, among other expenses, medical and dental              
          expenses to the extent such expenses exceed 7.5 percent of                  
          adjusted gross income.  In this case, petitioner claimed itemized           
          deductions for medical and dental expenses in the amounts of                
          $2,119 and $958 for 2002 and 2003, respectively.  Petitioner                
          attached receipts to his returns in substantiation of these                 
          expenses.  Respondent determined that the documentation                     
          petitioner submitted for these expenses was falsified and                   
          disallowed all of petitioner’s claimed Schedule A deductions.               
               At trial, respondent presented several witnesses, including            
          doctors who petitioner claimed had provided services.  These                
          doctors testified that no medical services had been provided by             
          them to petitioner during the years at issue and that the                   
          receipts petitioner relied on were for services provided to him             
          in prior years that had been altered to reflect dates in 2002 and           

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Last modified: May 25, 2011