- 5 - area, common court yard, large kitchen, dining and living rooms, 11 bedrooms, 6 or 7 bathrooms, private quarters for Reverend McWilliams and his family, covered parking for 12 automobiles, and a trailer in the back. Petitioners occupied one room and their three children occupied another room. They shared a bathroom. Petitioners made monthly rental payments to Reverend McWilliams. The rental payments covered room and board, utilities, and other living expenses. Petitioners claim they paid rent to Reverend McWilliams in the amount of $14,300 per year in 1991 and 1992 for these services. The canceled checks and carbon copies of checks placed in evidence do not add up to this amount for claimed rental payments for either year. On Schedules A of their 1991 and 1992 Federal income tax returns, petitioners claimed deductions for charitable contributions in the amounts of $16,176.48 and $17,940.00, respectively. Respondent disallowed the charitable contribution deductions for 1991 and 1992 because the contributions were not made to a qualified organization, because the contributions were made for the benefit of a specified individual, and because petitioners failed to establish that the amounts claimed were contributions and were paid. Respondent concedes that contributions that werePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011