Anthony W. Jorgenson and Florence A. Jorgenson - Page 10




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          had substantiated expenses of $64,397 with regard to the St. John           
          rental property for the 1994 taxable year.  Respondent determined           
          that of the $64,397 expenses allowed to petitioners and the                 
          Trust, petitioners were entitled to deduct only one-half.                   
          Respondent disallowed the rest of the deductions claimed by                 
          petitioners for lack of substantiation.  During the years in                
          issue, in addition to the St. John rental property, petitioners             
          maintained several other rental properties in Nacogdoches, Texas,           
          for which they claimed various tax deductions.                              
          Charitable Contributions                                                    
               In 1993 and 1994, petitioners made noncash charitable                  
          contributions to two qualified charitable organizations as                  
          described in section 170(c)(1).  In 1993, petitioners donated a             
          sliding wall partition (partition) having a fair market value of            
          $10,000 to the Boys and Girls Club of Nacogdoches (the Club).  In           
          1994, petitioners donated a 1989 Chevrolet Suburban (Suburban)              
          having a fair market value of $14,850 to the Sacred Heart                   
          Catholic Church.                                                            
               The Internal Revenue Service (IRS) provides taxpayers with             
          Form 8283 to report information related to noncash charitable               
          contributions on their tax returns.  In their 1993 tax return,              
          petitioners attached the second page of Form 8283 and a letter              
          from the executive director of the Club to petitioners thanking             
          them for the partition.  On the second page of Form 8283,                   
          petitioners described the partition as a “Sliding Partition Wall”           




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