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In addition, petitioners provided copies of checks totaling
$7,000 paid as tuition to the Yeshiva Rav Isacsohn Torath Emeth
Academy (Yeshiva Rav Isacsohn). Petitioners also provided checks
totaling $17,146 in tuition payments to the Emek Hebrew Academy
(Emek). Yeshiva Rav Isacsohn and Emek are collectively referred
to as the schools. The amounts paid to the schools in 1994 total
$24,146.
In July 1996, during the examination of their 1994 return,
petitioners presented letters from each school which acknowledge
receipt of the amounts paid and state unequivocally that the
payments were applied toward the tuition of petitioners’ children
for their religious and secular education. Each letter also
states that the school estimates that the total education
comprised 55 percent religious education and 45 percent secular
education. According to petitioners, they calculated their
claimed 1994 “religious education” deduction in the amount of
$13,240 by multiplying by 55 percent the total tuition payments
to the schools.2
Emek and Yeshiva Rav Isacsohn are organizations recognized
to be exempt from Federal income tax under section 501(c)(3).
They are classified for Federal income tax purposes as
organizations that are not private foundations as defined in
2 There is a $40 unexplained discrepancy.
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Last modified: May 25, 2011