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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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Last modified: May 25, 2011