- 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
Last modified: May 25, 2011