Herbert Donald Singer - Page 3




                                        - 2 -                                         
               Respondent determined deficiencies in petitioner’s Federal             
          income taxes and accuracy-related penalties for 1996 and 1997 as            
          follows:                                                                    
                                             Penalty                                  
                    Year      Deficiency     Sec. 6662                                
                    1996      $11,370        $2,274                                   
                    1997        16,359         3,271                                  

               After a concession by respondent,2 the issues remaining for            
          decision are as follows:                                                    
               (1) Whether petitioner engaged in his “health, wealth and              
          healing ministry” activity for profit within the meaning of                 
          section 183 during each of the years in issue.  We hold that he             
          did not.                                                                    
               (2) Whether petitioner is entitled to deductions for his               
          “health, wealth and healing ministry” activity for 1997.  We hold           
          that he is not.                                                             
               (3) Whether petitioner is entitled to a deduction for                  
          charitable contributions for 1997 in an amount greater than that            
          conceded by respondent.  We hold that he is not.                            
               (4) Whether petitioner is liable for the accuracy-related              
          penalty under section 6662(a) for negligence or intentional                 
          disregard of rules or regulations for each of the years in issue.           


               2 Respondent concedes that petitioner is entitled to a                 
          deduction for charitable contributions in 1997 in the amount of             
          $1,500.  The extent, if any, to which this concession may have a            
          tax effect will be determined by the parties in their Rule 155              
          computation.  See sec. 63(c).                                               




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