- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: By notice of deficiency dated November 4, 2003 (the Notice), respondent determined deficiencies in petitioner’s Federal income tax liabilities of $2,114 and $2,499 for her taxable (calendar) years 2000 and 2001 (the audit years), respectively, and accuracy-related penalties of $422.80 and $499.80 for 2000 and 2001, respectively. At the trial of this case, petitioner conceded respondent’s denial, for lack of substantiation, of her reported capital loss of $1,733 and respondent’s application of the 10-percent additional tax under section 72(t), in the sum of $849, on a premature distribution from her individual retirement account. On brief, respondent concedes a 2001 cash contribution by petitioner of $713. The issues for decision are (1) whether petitioner is entitled to certain charitable contribution deductions for the audit years and (2) whether petitioner is liable for the accuracy-related penalties determined by respondent under section 6662(a). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the audit years, and all Rule references are to the Tax Court Rules of Practice and Procedure. All dollar amounts have been rounded to the nearest dollar.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011