T.C. Memo. 2006-165
UNITED STATES TAX COURT
ALFONSO J. AND ELENA L. DIAZ DEL CASTILLO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1514-05. Filed August 14, 2006.
Alfonso J. and Elena L. Diaz Del Castillo, pro sese.
Scott A. Hovey, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge: Respondent determined a $2,327.40 deficiency
in petitioners’ 2001 Federal income tax. Respondent’s
determination was based on the disallowance of a deduction
claimed on petitioners’ 2001 joint Federal income tax return for
an $8,448 charitable contribution carryover. Petitioners
contend, alternatively, that they are not liable for the
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