The Best Tax Court Memo in a Long Time…

In Uncategorized on 12/09/2010 at 17:08

In Griffin v. Comm’r, T.C. Memo. 2010-252 (11/17/10), the Tax Court gets an early holiday gift in the form of the testimony and documentary evidence (or lack thereof) of Sharon Louise Griffin in defense of her U.S. Federal income tax returns for the years 2001 through 2003. Ms. Griffin worked part time as a videotape operator and technician. But, if her returns are to be believed, she operated nine businesses in her spare time, grossing $2,876,957 during 2001-2003, but with operating losses each year.


Highlights include (but are certainly not limited to):


  • “This is either a transcription error of “hog wild” or “off the hook” or a level of craziness with which the Court is unfamiliar.”
  • “An IRS agent credibly testified about his effort to contact VCR Gary to verify the claimed expenses by calling several different telephone numbers, all of which had been disconnected. Griffin explained that VCR Gary ‘has passed away in the sense of the guy who’s VCR Gary.’”
  • “In Griffin’s records, for example, the name “Xander” appeared five times and “Zander” appeared six times. They were presumably different people because each Xander or Zander had a different surname. According to the Commissioner’s investigation, there are very few Xanders or Zanders in the entire state of California–about 85 Xanders and 95 Zanders. Griffin either had an uncanny ability to find Xanders/Zanders, or her cash receipts are unreliable evidence. We do not believe the former possibility.”


Read the full Memorandum here.

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