Dieter Stussy - Page 2
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through 1994 taxable years. Respondent determined the following
income tax deficiencies and penalties for those years:
Year Deficiency 6662(a)
1992 $8,316 $1,663
1993 8,014 1,603
1994 3,011 602
The primary issue we must decide is whether petitioner is
entitled to the charitable contribution carryovers that he
reported for the subject years. We hold he is not. We also
decide whether petitioner is liable for the penalties determined
by respondent under section 6662(a). We hold he is not.
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and exhibits submitted therewith are
incorporated herein by this reference.1 Petitioner resided in
Los Angeles, California, when he petitioned the Court. He filed
1992, 1993, and 1994 Federal income tax returns and a 1992
amended return. His 1992 amended return, 1993 return, and 1994
1 Petitioner submitted some documents with his brief that he
claims were omitted from the stipulated exhibits. We have not
relied on these documents. See West 80 Street Garage Co. v.
Commissioner, 12 B.T.A. 798, 800 (1928); see also Saunders v.
Commissioner, T.C. Memo. 1992-361, and the cases cited therein.
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