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Background
Petitioner resided in Inglewood, California, when the
petition in this case was filed.
Petitioner claimed a charitable contribution deduction of
$14,800 on his 2001 income tax return.2 Following an
examination, respondent issued an examination report in which he
proposed to disallow $14,345 of petitioner’s reported
contributions. On November 4, 2003, respondent issued a revised
examination report in which he proposed to disallow only $10,545
of petitioner’s reported contributions.3 The letter accompanying
1(...continued)
filed, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
2Petitioner claimed deductions for the following charitable
contributions:
Donee organization Amount of contribution
Administrator of Peace and
Brotherhood Ministries (APB
Ministries) $10,500
True Vine Baptist Church 3,800
Marantha Community Church 455
Miscellaneous 45
Total 14,800
3Respondent originally only allowed a deduction for the $455
paid to Marantha Community Church. Respondent received an
itemized list of contributions made to True Vine Baptist Church,
however, and he allowed the $3,800 deduction in the revised
examination report. Respondent disallowed the $10,500
contribution to APB Ministries because APB Ministries did not
respond to a request by respondent for additional documentation
regarding petitioner’s alleged contribution. Respondent also
disallowed the remaining $45 miscellaneous contribution(s) not
(continued...)
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Last modified: May 25, 2011