- 6 - petitioner contributed equipment to RRS and provided the organization with related services, such as repairing and setting up the equipment.5 The Examination of Petitioner’s Tax Returns and the Present Litigation In approximately 2001, the Internal Revenue Service began an examination of petitioner’s 1998, 1999, and 2000 tax returns. Petitioner’s case was assigned to Revenue Agent John Leahy. Petitioner and Agent Leahy first met on September 19, 2001. The only documentation petitioner provided Agent Leahy at the September 19 meeting was a receipt,6 purportedly from RRS, dated 4(...continued) from taxation as an organization described in sec. 501(c)(3) for 1998, 1999, or 2000 and that RRS has not filed any tax forms with respondent for the periods ending Dec. 31, 1998, through Dec. 31, 2000. 5Petitioner testified at trial that he donated equipment to RRS in 1998 and 1999, that he provided services to RRS in 1999, that his total donations for 2000 were made to the Church of Jesus Christ of Latter Day Saints, and that he donated nothing to RRS in that year. Respondent’s requests for admission include statements that petitioner provided services to RRS in 1998, 1999, and 2000. In petitioner’s correspondence with respondent during the examination of his returns, petitioner refers to contributions he claims to have made to RRS, but he does not mention any contributions to any other entity. 6The receipt also states: [PETITIONER’S] * * * CONTRIBUTIONS WERE USE [sic] TO BUILD HOMES IN OUR BLS PROGRAM, TO PROVIDE AFFORDABLE HOUSING FOR THE POOR, AND FEED THE POOR ALL OVER THE WORLD WITH OUR INTERNATIONAL FEEDING PROGRAM. * * * * * * * (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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