- 8 -
Petitioner also stated in the letter that
most of the donations consisted of sound and video
electronics, computers, and networking equipment.
Another large portion of the donation was labor that
was billed out by [RRS] for my services for repairing
and setting up the computers I donated, and others that
the Society got elsewhere. The donations were recorded
as cash because that is what they were paid for my
equipment and services. 90 percent of the actual money
I gave the Society was by receipt for computer parts I
purchased * * *.
In a letter dated April 25, 2002, petitioner represented that
“All payments for my services were paid to me, and I gave them
back to [RRS] as contributions.”
On or about January 29, 2003, respondent mailed a notice of
deficiency to petitioner in which he disallowed petitioner’s
charitable contributions, determined that petitioner had
unreported income attributable to services he had rendered to RRS
during 1999, disallowed the dependency exemptions and child tax
credits for petitioner’s three daughters for 1998 and 1999, and
determined that petitioner owed additional income tax for each of
the years at issue.
On April 22, 2003, we received and filed petitioner’s
petition contesting respondent’s adjustments. On June 16, 2003,
we received and filed respondent’s answer to the petition. On
September 24, 2003, we served notice on the parties that the case
was calendared for trial at the Court’s Seattle, Washington,
trial session beginning February 23, 2004. Attached to the
notice was our Standing Pretrial Order, which required the
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