Bobby E. Welch - Page 4

                                        - 4 -                                         
                         1988           78,231                                        
                         1989           117,865                                       
                         1990           165,843                                       

               In October 1987, petitioner claimed that since 1986 he had             
          made contributions totaling approximately $164,000 to the Church            
          of Scientology (the church).  On the 1986 Federal income tax                
          return, petitioner claimed no deduction for these contributions.            
          On a 1987 return attached to the petition,1 petitioner showed a             
          $5,787 charitable contribution and a carryover from the prior               
          year in the amount of $51,010.  On the 1989 return, petitioner              
          showed a contribution to the church in the amount of $57,998 and            
          a carryover from the prior year in the amount of $56,797.  On the           
          1990 return, petitioner showed charitable contributions in the              
          amount of $74,055 and a carryover from prior years in the amount            
          of $105,885.                                                                
               With respect to the unreported income, the gravamens of                
          petitioner's arguments are that the balances in dispute were                
          either loans from Stanley Zurn (Mr. Zurn) in the amounts of                 
          $375,000 in 1986, $70,000 to $75,000 in 1988, $70,000 in 1989,              



               1  The record contains two 1987 tax returns.  A copy of one            
          return was attached to the petition.  That return, prepared by              
          Arthur T. Moore, a certified public accountant, is a joint                  
          return, and shows the charitable contribution and carryover                 
          amounts.  The second return is Exhibit 4-D attached to the                  
          stipulation of facts.  That return, prepared by William D. Truax,           
          E.A., Inc., has a filing status of married filing separate and              
          claims no charitable contribution or carryover.  The record is              
          silent concerning this anomaly.                                             




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011