John Andrew Dorris and Donna L. Dorris - Page 5

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          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 were            







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