- 2 - 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 conclusion.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011