Nathaniel L. Ward, Sr. and Irene E. Ward - Page 4

                                        - 4 -                                         
          motive for 1992 and 1993.  Petitioner did not have any knowledge            
          of the value of timber in place or whether his claimed losses had           
          any relevance to the amount of gain he might have earned from               
          their harvest.  Petitioner’s focus was on developing a tree farm            
          for his children or the next generation.  Petitioners did not               
          produce any documentary evidence supporting the deductions                  
          claimed on their Schedules F.                                               
               Petitioners, in connection with their professional                     
          employment as teachers, paid union dues and purchased equipment             
          and teaching aids.  Petitioners claimed employee business                   
          expenses on Schedule A of their 1992 and 1993 returns in the                
          respective amounts of $3,691.42 and $4,605.  At trial,                      
          petitioners offered documentary evidence which corroborated                 
          amounts that were substantially less than those claimed on their            
          1992 and 1993 returns.                                                      
               Petitioners claimed contributions to charity by cash or                
          check in 1991, 1992, and 1993 in the respective amounts of                  
          $3,530, $3,470, and $3,160.  At trial, petitioners presented                
          documentary evidence substantiating $10 and $25 of contributions            
          for 1992 and 1993, respectively, and no documentary evidence was            
          presented for 1991.  Petitioner contended that he and his wife              
          tithed at a 10-percent rate during the years in question, which             
          would have resulted in contributions of $8,000 in each year under           
          consideration.  He offered the explanation that he claimed only             
          about $3,000 in each year because larger claims might have                  




Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011