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deficiency stated: “Since these costs are personal tuition
expenses, they are not deductible.” In a timely filed petition,
petitioners contend that they are entitled to the claimed
charitable contribution deductions on the grounds that the
amounts in question are similar to those paid for auditing to the
Church of Scientology, which petitioners allege the Internal
Revenue Service (IRS) has allowed as charitable contributions.
Thus petitioners contend that respondent’s position is a
violation of the Establishment Clause of the First Amendment to
the Constitution of the United States.
Background
Some of the facts have been stipulated and are so found.
Petitioners resided in North Hollywood, California, at the time
of the filing of their petition. The following facts are not in
dispute.
On their 1994 joint Federal income tax return, which was
filed on November 27, 1995, petitioners claimed a deduction for
charitable contributions in the amount of $23,996. Petitioners’
1994 return was examined by respondent, and the charitable
contribution deduction was questioned. During the examination,
petitioners provided copies of checks totaling $10,756 that
qualified as charitable contributions, and this amount was not
disallowed.
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Last modified: May 25, 2011