Jack Lane Taylor - Page 2

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          whether petitioner is entitled to a deduction for a charitable              
          contribution under section 170.1  We hold that he is not.                   
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and they are so                
          found.  Petitioner resided in Indianapolis, Indiana, at the time            
          that his petition was filed with the Court.                                 
               During the year in issue, petitioner donated $8,647 to the             
          Indianapolis Baptist Temple (IBT).2  In the previous year, on May           
          8, 1995, the Service had determined that IBT no longer qualified            
          as an organization described in section 170(c)(2) and by                    
          Announcement 95-35, 1995-19 I.R.B. 14, deleted IBT from the list            
          of organizations contributions to which are deductible under                
          section 170.                                                                
               On his joint 1996 Federal income tax return, petitioner                
          claimed a deduction in the amount of $8,647 for a charitable                
          contribution.  By notice of deficiency, respondent determined               
          that petitioner was not entitled to any deduction for a                     
          charitable contribution because petitioner had failed to                    
          substantiate any such contribution, and further, that IBT was not           

          1  All section references are to the Internal Revenue Code,                 
          as amended, and all Rule references are to the Tax Court Rules of           
          Practice and Procedure.                                                     
          2  Throughout this opinion we use the words “donation” and                  
          “donate” for convenience only and not to imply any legal                    

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