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business address at the time of incorporation was the same as
petitioner’s personal home address. Petitioner opened a
corporate bank account on behalf of the Center with Nationsbank
and listed himself as the sole authorized signatory.2 Petitioner
also installed an additional phone line in his home in the name
of “Gillis Triplett d/b/a/ Embassy Christian Center, Inc.”
Petitioner filed his 1998, 1999, and 2000 Federal income tax
returns untimely on April 1, 2002. He filed his 2001 Federal
income tax return timely. During the years in question,
petitioner reported total income and claimed deductions for
charitable contributions in the following amounts:3
Year Total Income Charitable Contributions
1998 $41,635 $18,831
1999 33,097 16,549
2000 32,968 16,484
2001 40,593 20,297
Respondent disallowed all the claimed charitable
contributions deductions due to lack of substantiation.
2Petitioner testified that the Center had a treasurer for
some of the time during the years at issue who was authorized to
issue checks from the account, but he offered no evidence in
support of this testimony. Regardless, petitioner was authorized
to write checks on behalf of the Center at all times during the
years at issue.
3The amounts listed on the notice of deficiency sent to
petitioner differ slightly from those referred to during trial
and in this opinion. The true amounts, listed herein, are taken
from petitioner’s 1998, 1999, 2000, and 2001 Federal income tax
returns. The difference in the amounts, however, is so nominal
that a Rule 155 computation is unnecessary.
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