Attorney-at-Law

INSUBSTANTIATION

In Uncategorized on 01/08/2025 at 19:20

Most indocumentados are cases involving little, few, or no papers. But Ishveen K. Chopra, T. C. Memo. 2025-2, filed 1/8/25, has a lot of papers. Only they don’t substantiate her claimed deductions.

Judge Albert G. (“Scholar Al”) Lauber spends seventeen (count ’em, seventeen) pages demolishing Ishveen’s paperwork.

A sample. “One group of statements showed alleged transactions on an American Express (AmEx) account ending in 15008; the other showed alleged transactions on a Discover Bank (Discover) account ending in 4260. The RA noticed inconsistencies in these statements, which prompted him to issue a summons to Discover. Discover supplied the IRS with information about all Discover accounts in petitioner’s name for [year at issue]. They did not include any account ending in 4260.” T. C. Memo. 2024-2, at p. 3.

“Hotel receipts misspelled the hotel’s name and had unusually late checkout times (such as 11:10 p.m.).” T. C. Memo. 2024-2, at p. 3.

There’s a lot more, enough to get Ishveen the 75% fraud chop.

Maybe sometimes it’s better not to substantiate.

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