Brandt N. Castleton - Page 6

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          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...)           




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