- 13 - charitable contribution deduction. Litigation relating to petitioners’ 1994 return is discussed below at paragraph E. 3. 1995 Petitioners timely filed their 1995 Federal income tax return on October 15, 1996. Petitioners deducted $24,421 as a charitable contribution for 1995, including $15,000 which petitioners attributed to the cost of their children’s religious education at Emek and Yeshiva Rav Isacsohn during 1995. That amount ($15,000) is 54.97 percent (referred to here as 55 percent) of the total amount of tuition and fees that petitioners paid to Emek and Yeshiva Rav Isacsohn during 1995. Petitioners did not file a Form 8275 or otherwise describe their payment on their 1995 return. Respondent had petitioners’ 1994 return under examination when petitioners filed their 1995 return. Pursuant to petitioner’s request, Emek and Yeshiva Rav Isacsohn issued letters to petitioner dated November 5 and November 10, 1997, respectively, in which each school estimated that 45 percent of the education provided to petitioners’ children was secular and 55 percent was religious. E. Litigation Relating to Petitioners’ 1994 Return Petitioners filed a petition with the Court challenging respondent’s notice of deficiency for 1994. In Sklar v. Commissioner, T.C. Memo. 2000-118 (Sklar I), this Court held that petitioners could not deduct as charitable contributions amountsPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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