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Florida; Miami Beach, Florida; Richmond, Virginia; Jacksonville,
Florida; Virginia Beach, Virginia; Nassau, Bahamas; St.
Augustine, Florida; Montgomery, Alabama; Birmingham, Alabama;
Athens, Greece; and Istanbul, Turkey.
On his 1990 and 1991 Federal income tax returns petitioner
deducted charitable contributions in the amounts of $29,105 and
$40,603,3 respectively. The bulk of these amounts consisted of
unreimbursed expenses incurred during the above listed trips.
Petitioner asserts that these expenditures were incurred in the
process of providing services to the Greek Orthodox Church, St.
Photios, and AHEPA. Typically, the amounts claimed as expenses
for any given trip include airfare, lodging at a deluxe hotel,
meals, other travel expenses, and generous tips (occasionally
exceeding $100). Petitioner generally included, as an expense
for meals, the bill from an expensive lunch or dinner at which
petitioner treated numerous people attending the meeting. The
1990 figure includes a $1,000 deduction for clothing donated to
the Crossnore School.
In the notice of deficiency, respondent disallowed
charitable contribution deductions for the taxable years 1990 and
1991 in the amounts of $11,177 and $14,492, respectively. After
concessions, the amount of charitable contribution deductions in
3 The deduction claimed in 1991 was reduced to $37,074
pursuant to sec. 170(b), which limits the amount a taxpayer can
deduct as a charitable contribution for any taxable year.
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