- 7 -
loss. Zmuda v. Commissioner, 79 T.C. 714, 727 (1982), affd. 731
F.2d 1417 (9th Cir. 1984).
Charitable Contributions--1989, 1990, and 1991
Respondent disallowed all claimed charitable contribution
deductions on petitioners' 1989, 1990, and 1991 returns.
Petitioners claimed $3,490, $5,010, and $4,220 in 1989, 1990, and
1991, respectively, for deductions for gifts to charity.
At trial, petitioners testified regarding the churches they
attended, the church pastors' names, and the frequency of their
church attendance. Petitioners claimed that they each gave $35
to $40 cash on every occasion that they attended church.
Petitioners' testimony was the only evidence presented. They now
assert that they are entitled to deduct $2,400 per year--
substantially less than they claimed on their returns.
We conclude that petitioners' testimony as to the
contributed amounts is not reliable. We have found, however,
that petitioners attended church during the years in issue and
made cash contributions to the churches they attended. We
conclude that petitioners are entitled to a deduction of $500 for
gifts to charity in each of the years in issue. See Cohan v.
Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930).
Other Deductions--1991
In the notice of deficiency, respondent determined that
petitioners were entitled to deduct $9,698 of cash expenses on
their 1991 Schedule C. Respondent has allowed an additional
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011