John Andrew Dorris and Donna L. Dorris - Page 2

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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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