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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.
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