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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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