- 2 -
Respondent determined deficiencies in Federal income taxes
of $1,672, and $1,597, and accuracy-related penalties of $334,
and $319, for the respective years 1995 and 1996. Petitioners
concede that they are not entitled to deductions for unreimbursed
employee business expenses for 1995 and 1996 or for charitable
contributions for 1996. The issues for decision are whether
petitioners are entitled to deductions for charitable
contributions claimed for 1995 and whether petitioners are liable
for the accuracy-related penalties for 1995 and 1996.
A few of the facts have been stipulated and are so found.
The accompanying exhibits are incorporated herein by reference.
Background
Petitioners resided in Philadelphia, Pennsylvania, at the
time their petition was filed in this case.
The parties agree that petitioners have no receipts to
substantiate the $8,275 of charitable contributions claimed on
their 1995 joint Federal income tax return. Marshall Stewart
Gardner (petitioner) produced at trial, however, an undated sheet
of paper containing various handwritten items and amounts. The
items were "estimates", according to petitioner, based on "How
many times I might have given". The sheet, stated petitioner,
was used by him in the preparation of his joint tax return for
1995.
Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011