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supported his charitable contribution deduction of $7,500 in
2000. That letter purportedly from Special Friends thanked
petitioner for his donation of golf clubs and for an
advertisement placed with the organization’s newsletter and said
that the bill for the advertisement would be charged to
petitioner’s Visa credit card in two installments of $3,750.
That letter was not an accurate copy of any letter from
Special Friends. The letter that Special Friends sent to
petitioner acknowledged his donation of golf clubs but did not
mention any other contribution from petitioner. Petitioners did
not contribute $7,500 to Special Friends in 2000 or provide to
Hughs any record of Visa card payments to Special Friends.
During the audit, petitioner gave Hughs inconsistent and
incorrect explanations of the purpose of the $27,000 payment to
Pekas in 2000. He told Hughs that he paid $27,000 to Pekas in
2000 for investment counseling. Petitioner also told Hughs
during the audit that he paid $27,000 to Davoli in 2000 to obtain
a background investigation so he could qualify for appointed
Government service. Petitioner told Hughs at a different time
during the audit that the $27,000 payments were for legal fees.
Respondent issued the notice of deficiency to petitioners
for 1999, 2000, and 2001 on January 16, 2003.
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