John C. and Tate M. Todd - Page 2




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               Richard C. Kaufman, for petitioners.                                   
               Frederick J. Lockhart, Jr., for respondent.                            


               HALPERN, Judge:  By notice of deficiency dated August 13,              
          1999 (the notice), respondent determined deficiencies in                    
          petitioners’ Federal income tax liabilities for petitioners’                
          taxable (calendar) years 1994 through 1997 (the audit years) of             
          $14,181, $61,540, $88,832, and $33,971, respectively.  Among the            
          adjustments giving rise to respondent’s determination of                    
          deficiencies is respondent’s disallowance of deductions for                 
          charitable contributions petitioners claimed for each of the                
          audit years (the disallowed deductions).  Petitioners have                  
          assigned error only with respect to that disallowance.                      
          Accordingly, we need decide only whether petitioners are entitled           
          to the disallowed deductions, all other adjustments being deemed            
          conceded by petitioners.  See Rule 34(b)(4).                                
               Unless otherwise noted, all section references are to the              
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.  Petitioners bear the burden of proof.  See Rule                 
          142(a).                                                                     











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