John Andrew Dorris and Donna L. Dorris - Page 8

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          total amounts listed in the respective donation ledgers.  The               
          record does not establish the reason for this difference.                   
               We also find petitioner not credible.  We are troubled by              
          petitioner's testimony that although he was Agape's president and           
          one of its incorporators, he had no knowledge of how much Agape             
          paid Reverend McWilliams for his services, nor did he know                  
          whether or not Ms. Spiegel always deposited the contributions               
          into the TFC account.  Moreover, petitioner could not explain               
          where the money went after petitioners gave it to Ms. Spiegel.              
          Petitioner also had difficulty explaining why the payee lines               
          were left blank.                                                            
               On the basis of this record, we find that petitioners failed           
          to establish that the amounts of the purported charitable                   
          contributions at issue were to or for the use of Agape within the           
          meaning of section 170(c).  Accordingly, respondent is sustained            
          on this issue.                                                              
               Finally, we must decide whether petitioners are liable for             
          accuracy-related penalties in the amounts of $309 and $359 for              
          1991 and 1992, respectively.  Section 6662(a) imposes an                    
          accuracy-related penalty in the amount of 20 percent of the                 
          portion of an underpayment of tax attributable to negligence or             
          disregard of rules or regulations.  Sec. 6662(a) and (b)(1).                
          Negligence is any failure to make a reasonable attempt to comply            
          with the provisions of the Internal Revenue laws.  Sec. 6662(c);            





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