Stanley Joseph Jennings - Page 2




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               Petitioner contends that he made charitable gifts of cash,             
          property, and articles to be published.  Following concessions,1            
          the issues for decision are:                                                
               1.   Whether petitioner is entitled to deduct charitable               
          contributions of $36,960.30 for 1994, $25,028.40 for 1995, and              
          $32,522.32 for 1996, as he contends, zero as respondent contends,           
          or some other amount.  We hold that he may not deduct any                   
          charitable contributions for the years in issue.                            
               2.   Whether petitioner is liable for the accuracy-related             
          penalties under section 6662(a).  We hold that he is.                       
               Section references are to the Internal Revenue Code in                 
          effect during the years in issue.  Rule references are to the Tax           
          Court Rules of Practice and Procedure.                                      
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          Petitioner lived in Lima, Ohio, when the petition was filed.  He            
          worked for the Ford Motor Co. in the years in issue.                        




               1  Petitioner concedes that he may not deduct amounts that             
          he paid for a banquet for his parents, gasoline, dental care,               
          lawn care, household repairs, and maintenance.  In the notice of            
          deficiency, respondent disallowed petitioner’s $2,000 IRA                   
          contribution for 1996.  Petitioner offered no evidence and makes            
          no argument on this issue.  Thus, petitioner has conceded this              
          issue.  See, e.g., Bradley v. Commissioner, 100 T.C. 367, 370               
          (1993); Sundstrand Corp. v. Commissioner, 96 T.C. 226, 344                  
          (1991); Rybak v. Commissioner, 91 T.C. 524, 566 n.19 (1988);                
          Money v. Commissioner, 89 T.C. 46, 48 (1987); Leahy v.                      
          Commissioner, 87 T.C. 56, 73-74 (1986).                                     




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