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Church during 1995 and 1996. Petitioner serves as one of its
deacons. He is the Church historian and, as such, provides
services as a photographer. Petitioners regularly attended
Church services and made cash and personal property contributions
to it during 1995 and 1996. As an official of the Church,
petitioner attended various Church meetings regularly.
During both years in issue, petitioners also made cash and
personal property donations to various other organizations. They
maintained at least one checking account (the account). Some of
the cash donations made to the Church and other organizations
were made through the account. It appears that canceled checks
drawn on the account were not routinely returned to petitioners.
Instead, a carbon copy of the check was created each time a check
was written, and petitioners retained those carbon copies. For
the year 1995, there are carbon copies of 11 checks, each for
$250, payable to the Baptist Health Foundation. According to the
records of the Baptist Health Foundation, petitioners made no
donations to that organization in 1995 or 1996.
Petitioners filed a timely joint Federal income tax return
for each year in issue. Included with each return is a Schedule
C, Profit or Loss from Business, on which they reported the
following items:
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Last modified: May 25, 2011