2
Respondent determined deficiencies in Federal income taxes as
follows:
Women of the Motion Picture Industry (WMPI):
Tax Year Ending Deficiency
June 30, 1990 $2,435.00
Family Service of El Paso, Inc. (FSEP):
Tax Year Ending Deficiency
Dec. 31, 1989 $1,471.00
Dec. 31, 1990 2,166.00
Schoenstatt, Inc. (Schoenstatt):
Tax Year Ending Deficiency
Sept. 30, 1988 $ 564.00
Sept. 30, 1989 2,092.00
Sept. 30, 1990 1,993.00
Sept. 30, 1991 2,168.00
Amarillo Council on Alcoholism and Drug Abuse (ACADA):
Tax Year Ending Deficiency
Dec. 31, 1989 $2,707.00
Waldorf School Association of Texas, Inc. (WSA):
Tax Year Ending Deficiency
Dec. 31, 1987 $ 735.00
Dec. 31, 1988 4,017.00
Dec. 31, 1989 5,208.00
After concessions set forth infra, the issues for decision
are whether (1) petitioners FSEP, Schoenstatt, ACADA, and WSA are
entitled to business expense deductions from unrelated business
taxable income (UBTI) for amounts allegedly expended for
charitable purposes in excess of amounts conceded by respondent,
2(...continued)
Procedure.
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