- 48 - Respondent has failed to establish that petitioner knew or believed that her former spouse was not engaged in the farming for profit. Accordingly, we hold petitioner is entitled to relief under section 6015(c) from the tax liability arising out of this activity. V. Charitable Contributions A. Background On their 1987 return, petitioners claimed a charitable contribution deduction of $5,556. Of this amount, $4,059 was listed as contributed to “1st United Methodist”. In 1987, petitioner wrote five checks to the St. Cloud First United Methodist Church on the NCNB account totaling $5,500. Respondent allowed the $5,556 charitable contribution deduction claimed on the 1987 return. On their 1988 return, petitioners claimed a charitable contribution deduction of $8,165. On the attached Schedule A, the claimed contribution was identified as “ERS-106, 1st United Meth. 8,059". Respondent disallowed the entire amount claimed as a charitable contribution deduction for 1988 on the ground that petitioners had failed to substantiate the charitable contribution. In 1988, neither petitioner nor Mr. Rowe wrote any checks on the NCNB account to the St. Cloud First United Methodist Church.Page: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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