Herbert Donald Singer - Page 11




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          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.                                       





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