Thomas M. and Dolores F. Gomez - Page 11




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          Habra Christian Church (also referred to as La Habra Episcopalian            
          Church) during a stewardship dinner in January 1993 and that the             
          funds to make the contribution were withdrawn from his bank                  
          account at the Certified Federal Credit Union the day before the             
          dinner.7  However, La Habra Christian Church had no record of any            
          charitable contribution, much less a substantial one, from                   
          petitioners during 1993.                                                     
               Similar claims were made concerning alleged contributions to            
          Calvary Chapel and/or Pacific Christian College.  Petitioner                 
          testified that petitioners made a cash contribution of $5,000 to             
          Pacific Christian College in November 1993 and a cash                        
          contribution of $5,000 to Calvary Chapel8 in December 1993.                  
          Petitioner also testified that, the day before each contribution             
          was made, petitioner withdrew the cash to make the contribution              
          from his bank account at Certified Federal Credit Union.                     
          However, Pacific Christian College, one of the alleged donees,               
          had no record of any charitable contribution, much less a                    
          substantial one, from petitioners during 1993, and the record                
          contains nothing to substantiate petitioner's testimony regarding            
          the alleged $5,000 gift to Calvary Chapel.                                   




               7We allowed the record to remain open for 30 days after                 
          completion of the trial to give petitioners an opportunity to                
          submit documentation such as their bank records in support of                
          their charitable contribution deductions.  Petitioners failed to             
          produce the documentation.                                                   
               8This testimony was not consistent with the listing of                  
          charitable contributions contained in petitioners' 1993 return.              
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