Roger F. and Carolyn R. Ellis - Page 12




                                       - 11 -                                         
          Church, the Christian Coalition, the Family Research Council,               
          Focus on the Family, the Forest Ridge Cub Scouts, and Goodwill              
          Industries; and (4) receipts for the purchase of various items of           
          personal property, which according to petitioners, were donated             
          directly to needy families, or to organizations that distributed            
          the donated property to needy families.  Also, at trial                     
          petitioners claimed that a portion of their charitable                      
          contribution deduction for each year consists of transportation             
          expenses that petitioner incurred to fulfill his obligations as             
          an official of the Church.                                                  
               We question the reliability of the carbon copies of checks             
          presented as substantiation for various cash contributions.  For            
          the year 1995, there are carbon copies of 11 checks, each for               
          $250, made payable to the Baptist Health Foundation.  According             
          to that organization, no donations were made by petitioners                 
          during that year.  Petitioner did not explain this inconsistency            
          at trial.  Ignoring the carbon copies of the checks, and taking             
          into account the receipts from the various organizations, we find           
          that for the year 1995, petitioners are not entitled to a                   
          charitable contribution deduction greater than the amount allowed           
          by respondent.  We further find that petitioners are entitled to            
          a charitable contribution deduction for the year 1996 in an                 
          amount computed as follows:                                                 








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  Next

Last modified: May 25, 2011