- 2 - through 1994 taxable years. Respondent determined the following income tax deficiencies and penalties for those years: Penalty Sec. 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.Page: Previous 1 2 3 4 5 6 7 8 Next
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