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Respondent determined the following deficiencies, section
6651(a)(1) addition to tax, and section 6662(a) penalties for the
1998, 1999, 2000, and 2001 taxable years:
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1998 $3,716 $100 $743.20
1999 2,483 -0- 496.60
2000 2,467 -0- 493.40
2001 3,440 -0- 688.00
The issues for decision are whether petitioner is entitled
to charitable contribution deductions claimed for 1998, 1999,
2000, and 2001, and whether he is liable for the section
6651(a)(1) addition to tax and the section 6662(a) penalties.
Some of the facts were stipulated. Those facts, with the
exhibits annexed thereto, are so found and made part hereof.
Petitioner’s legal residence at the time the petition was filed
was Mableton, Georgia.
During the years at issue, petitioner was employed on and
off as a sales trainer for Parmalat-Atlanta Dairies. He also
received unemployment compensation in the amount of $6,864 in
1999 and $1,582 in 2001. At trial, petitioner did not state the
current status of his employment. When employed, petitioner
worked 40 hours a week.
On May 16, 1994, petitioner incorporated Embassy Christian
Center, Inc. (the Center). Petitioner was listed as the
secretary, CEO, CFO, and Agent of the Center. The Center’s
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