- 2 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011