Gerald L. and Joy M. Zeidler - Page 5

                                        - 5 -                                         

          time in the past had applied with the Internal Revenue Service              
          (IRS) for recognition as a tax-exempt organization under section            
          501(c)(3); however, no determination was ever made by the IRS               
          that the organization was a qualified organization under section            
          501(c)(3).  The parties stipulated that the organization was not            
          listed as a tax-exempt nonprofit organization on the U.S.                   
          Department of Treasury Cumulative List of organizations pursuant            
          to section 501(c).  The organization never pursued its                      
          application for recognition as an organization exempt under                 
          section 501(c)(3).  In the notices of deficiency, respondent                
          disallowed the contributions for the 3 years.                               
               At the time of trial, the organization had been in existence           
          approximately 15 years.  It was made up of volunteer singers,               
          numbering approximately 45, from Greendale, Wisconsin, and its              
          environs who were interested in furthering the enjoyment of music           
          in the community and who, in general, "loved to sing".  The                 
          organization had two public performances each year, one in the              
          spring and one near Christmas.  Mrs. Zeidler was secretary of the           
          organization and also served on its executive board, having                 

          for 1992 is stated to be $193.  At trial, counsel for respondent            
          acknowledged that amount to be in error and that the correct                
          amount was $143.  Respondent agrees that the amounts at issue for           
          the 3 years were in fact paid by petitioners and that                       
          disallowance of the deduction was based solely on respondent's              
          determination that the organization was not an exempt charitable            
          organization under sec. 501(c)(3).                                          

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