Laura Elizabeth Mann, Docket No. 9643-23S, filed 6/5/24, tells a tale of a series of fraudulent returns filed in her name by an accountant to STJ Peter (“HB”) Panuthos, but only one of those returns is at issue, and Ms. Mann filed no other for that year.

STJ Panuthos tells us nothing about the source of the deficiency, but I cannot think it can be anything but third-party reporting.

Howbeit, Ms. Mann admits the deficiency.

“In her pleadings as well as at trial, petitioner acknowledged that the omitted income determined by respondent was not reported on her [year at issue] tax return. Further, petitioner indicated that the deficiency of $5,508 for [year at issue] was correct. However, petitioner contends that the filed [year at issue] return was not authorized to be filed by her, and that an accountant improperly and ‘fraudulently’ filed a return on her behalf. Petitioner also contends that the situation was similar for tax years [Year Minus Six] through [Year Minus One], in that returns were ‘fraudulently’ filed on her behalf.” Transcript, at p. 4.

IRS points out that none of the other “fraudulent” returns resulted in a deficiency.

It’s a most puzzling tale, but STJ Panuthos tells us nothing more, except that the out years are beyond his jurisdiction.

Deficiency confirmed, chops conceded.