- 12 -
portion of the tuition payments they made in 1991 to their
children’s schools. Respondent apparently believed that
petitioners were Scientologists, because in February 1994
respondent wrote to petitioners to request verification of their
payments to the Church of Scientology. By letter to respondent
in May 1994, petitioner stated that the deductions were based on
tuition he had paid for religious education for his children.
In August 1994, respondent sent a letter to petitioners,
again erroneously stating that petitioners’ payments were to the
Church of Scientology. Petitioner telephoned the author of that
letter to say that he was not a Scientologist. By letter dated
November 7, 1994, respondent told petitioners that respondent
allowed in full their claim for a refund for 1991.
2. 1992-94
Petitioners filed an amended 1992 return and a 1993 return
in which they deducted part of their children’s tuition as a
charitable contribution. Petitioners received a refund based on
the amended 1993 return, and respondent did not disallow the
deduction claimed on their 1993 return.
Petitioners deducted 55 percent of their payments to Emek
and Yeshiva Rav Isacsohn as a charitable contribution deduction
for 1994. Petitioners described the deduction on a Form 8275,
Disclosure Statement, attached to their 1994 return. Respondent
examined petitioners’ 1994 tax return and disallowed the
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011