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the year in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
Respondent determined a deficiency in petitioners’ Federal
income tax for the year 2003 in the amount of $4,283. The issue
for decision is whether petitioners are entitled to claim a
deduction in the amount of $23,211 for noncash charitable
contributions for the taxable year at issue.
Background
The stipulation of facts and the attached exhibits are
incorporated herein by reference. At the time the petition was
filed, petitioner resided in Shorewood, Wisconsin.
Petitioner husband (petitioner) was born and raised in
Nigeria, and immigrated to the United States to attend Texas
Christian University. After college, he received two master’s
degrees and a doctorate in education. He is employed with the
University of Wisconsin as a Professor of Education.
Petitioner was raised in a religious community in Nigeria
that emphasized charitable giving. As part of his religious
beliefs, petitioner gives amounts of cash and noncash items to
various churches and charitable organizations.
During the taxable year in issue, petitioners purportedly
made charitable contributions to St. Jude’s Hospital, Texas
Christian University, their church, and the Salvation Army.
Among the items that petitioners gave to the Salvation Army were:
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Last modified: November 10, 2007