Anthony W. Jorgenson and Florence A. Jorgenson - Page 24




                                       - 24 -                                         
          property expenses and the noncash charitable contributions.                 
          Petitioners provided no credible evidence for the claimed St.               
          John rental property deductions.  Further, neither petitioners              
          nor their accountant provided an explanation why timely qualified           
          appraisals were not conducted for the noncash charitable                    
          contributions and why the appraisal summaries on Form 8283 were             
          not fully completed.  We, therefore, sustain respondent’s                   
          imposition of the accuracy-related penalties with regard to the             
          underpayment associated with the deductions of the St. John                 
          rental property expenses and the noncash charitable                         
          contributions.                                                              
               In reaching our holdings herein, we have considered all                
          arguments made by the parties, and to the extent not mentioned              
          above, we find them to be irrelevant or without merit.                      
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             under Rule 155.                          


















Page:  Previous  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  

Last modified: May 25, 2011