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the years in issue. All Rule references are to the Tax Court
Rules of Practice and Procedure. Respondent determined the
following deficiencies in income tax and accuracy-related
penalties:
Accuracy-related Penalty
Year Deficiency Sec. 6662
1991 $1,545 $309
1992 1,793 359
The issues for decision are: (1) Whether petitioners are
entitled to charitable contribution deductions in the amounts of
$16,176 and $17,940 for 1991 and 1992, respectively, and (2)
whether petitioners are liable for accuracy-related penalties
under section 6662(a) for the taxable years at issue.
Some of the facts have been stipulated and are so found.
Petitioners resided in Reno, Nevada, at the time their petition
was filed.
Petitioners, and a third person unrelated to the issues
before us, incorporated Agape Assemblies (Agape) under the laws
of Texas as a nonprofit organization in July 1986. During the
taxable years at issue, petitioner John Andrew Dorris
(petitioner) served as Agape's president.
Agape operated as a social ministry. The purpose for which
Agape was organized was "to receive and maintain a fund or funds
of real or personal property, or both, and, * * * to use and
apply the whole or any part of the income therefrom and the
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