William Herbert Whitehurst, III and Carla Cherlene Whitehurst - Page 23




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          bowling scoring sheets that reflected most, but not all, of the             
          claimed deductions for the entry fees for the bowling tournaments           
          in which Mrs. Whitehurst competed.  On the basis of a review of             
          the evidence in the record, we are satisfied that petitioners are           
          entitled to deductions for entry fees of $8,700 in 1997, $7,968             
          in 1998, and $7,415 in 1999.                                                
          Issue 3.  Schedule A Itemized Deductions                                    
               a.  Charitable Contributions                                           
               Petitioners claimed deductions for charitable contributions            
          of $2,960 made in cash or by check and $500 made other than in              
          cash or by check for 1997, $2,570 made in cash or by check and              
          $500 made other than in cash or by check for 1998, and $2,255               
          made in cash or by check and $500 made other than in cash or by             
          check for 1999.                                                             
               The notice of deficiency disallowed the claimed deductions             
          for charitable contributions in part as follows:  $1,980 for                
          1997, $1,785 for 1998, and $1,628 for 1999.  Respondent                     
          disallowed portions of the claimed charitable contributions                 
          because petitioners did not substantiate the claimed amounts.               
               Section 170(a)(1) allows as a deduction a charitable                   
          contribution payment of which is made within the taxable year.  A           
          charitable contribution includes a contribution or gift to or for           
          the use of a corporation, trust, community chest, fund, or                  
          foundation organized and operated exclusively for religious,                






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