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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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Last modified: May 25, 2011