- 10 - cash or check”, petitioner attached to his return Form 8283, Noncash Charitable Contributions. On that form, petitioner identified United Cancer Research Society of Palm Springs, California, as the donee and described the donated property as “clothing, furniture, books, misc.” having a cost or adjusted basis of $36,000.5 G. The Notice of Deficiency In the notice of deficiency, respondent determined that petitioner’s “health, wealth and healing ministry” activity was not an activity engaged in for profit. Respondent also determined that petitioner failed to substantiate the expenses claimed on his Schedule C for 1997 and that such expenses were personal and not ordinary and necessary business expenses. In addition, respondent determined that petitioner is not entitled to a deduction for 1997 for charitable contributions. However, at trial, respondent conceded that petitioner was entitled to a $1,500 deduction for that year. Finally, respondent determined that petitioner is liable for the accuracy-related penalty under section 6662(a) for negligence or intentional disregard of rules or regulations for each year. 5 On a Schedule A for 1996, petitioner also claimed noncash gifts to United Cancer Research Society, describing the donated property as “clothing, books, housewares, TV, misc.” having a cost or adjusted basis of $12,000. Petitioner also claimed on his 1996 Schedule A a carryover of charitable contributions “from prior year” in the amount of $68,396.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011