- 3 - petitioners, primarily in the form of a “housing allowance”.2 Petitioner, upon receiving paychecks from unrelated employment, would sign the back of the paychecks over to Alpha Ministries prior to depositing them into a checking account bearing the designation “Alpha Ministries”. The account into which the funds were deposited was owned and controlled by petitioners, and petitioners alone had authority to use the funds therein. Petitioners filed joint Federal income tax returns for the years in issue. On these returns, petitioners claimed deductions of $27,150 in 1995 and $30,500 in 1996 for charitable contributions purportedly made to Alpha Ministries. In the statutory notice of deficiency, respondent disallowed these deductions in full. 2Petitioners, relying on uncorroborated summary documents entered into evidence, argue that Alpha Ministries had the following income and expenses for each of the years in issue: 1995 1996 Income Cash donations by petitioners $31,560 $25,740 Cash donations by other individuals 290 100 Interest on deposits 12 18 31,862 25,858 Disbursements Petitioner’s housing allowance $22,000 $24,775 Petitioner’s health care allowance 700 -0- Petitioner’s auto/travel allowance 700 200 Petitioner’s books and materials 94 -0- Loan to petitioner 8,135 -0- Supplies, postage, fees, and copies 34 -0- 31,663 24,975 Although we do not accept these figures as actual amounts of income and expenses of Alpha Ministries, we accept them as an admission by petitioners that any funds received by, or designated for use by, Alpha Ministries were used almost exclusively for the personal benefit of petitioners.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011