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(2) $1,258 of uniform expense;
(3) $468 of cell phone expense;
(4) $216 of pager expense;
(5) $185 of tax preparation fees; and
(6) $2,450 of attorney and accounting fees.
In her petition, petitioner maintains that she “was unaware and
not privy to what was filed” on the tax return submitted for
2002, and she requests relief from joint and several liability on
a joint return.
In support of her claimed deductions, petitioner provided
copies of certain checks and other documents. Many of the checks
appeared to be for personal expenses. For example, checks were
written to chain drugstores, department stores, discount stores,
and shoe stores, with no corroboration or explanation that the
items purchased were deductible items. An unsigned document
purportedly listing cash contributions was not accompanied by any
corroborating information, and no evidence of the contributions
was introduced at trial. Documents purporting to record noncash
charitable contributions contained what appeared to be
exaggerated and patently unreasonable amounts for used property
allegedly contributed to a charitable organization. The
organization shown on the purported receipts was not the
organization identified on the Form 1040.
At the time of trial, petitioner’s testimony focused on her
claim that her former husband recommended the tax preparer for
the 2002 tax return, that he subsequently failed to cooperate
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