Michael and Marla Sklar - Page 11

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          not apply to expulsion from secular studies or to registration              
          for the following school year.  The schools could refuse to                 
          register a student whose tuition payments were delinquent.                  
               If a student’s tuition payments became delinquent, e.g., if            
          a tuition check was not honored by the bank, both Emek and                  
          Yeshiva Rav Isacsohn would send letters demanding payment or                
          threatening to bar the student from attending secular classes.              
               The annual income from tuition and registration fees for               
          both schools typically covers about 65 to 75 percent of that                
          school’s annual operating expenses.  The rest of the annual                 
          operating expenses are funded with grants from the Bureau of                
          Jewish Education, interest income, and other fundraising.                   
          C.   Petitioners’ Payments of Tuition and Fees                              
               During 1995, petitioners paid a total of $27,283 to Emek and           
          Yeshiva Rav Isacsohn for tuition, registration and other                    
          mandatory fees, and Mishna classes as follows:                              
               Payment                    Emek     Yeshiva Rav Isacsohn               
               Tuition                  $16,043        $8,050                         
               Registration fees        900            400                            
               Mishna classes           175            -0-                            
               Other                    1,215          500                            
               Total                    18,333         8,950                          
          D. Petitioners’ Tax Returns                                                 
               1.   1991                                                              
               Petitioners filed an amended tax return for 1991 in December           
          1993, in which they deducted as a charitable contribution a                 






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