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Respondent determined deficiencies in petitioner’s Federal
income taxes of $1,755 in 2002 and $1,500 in 2003. The only
issue for decision is whether petitioner is entitled to itemized
deductions for charitable contributions of $6,500 for 2002 and
$6,000 for 2003.
Some facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
by this reference. When the petition was filed, petitioner
resided in Wilmington, Delaware.
Respondent received petitioner’s electronically filed
Federal income tax returns for 2002 and 2003 on May 21, 2003, and
April 30, 2004, respectively. Petitioner’s returns were prepared
by Chester Muhammad. Petitioner claimed itemized deductions for
charitable contributions of $6,500 and $6,000 for 2002 and 2003,
respectively.
During the examination of petitioner’s returns, petitioner
submitted computer-generated lists which show weekly cash
charitable contributions to Faith Tabernacle Church (the church)
of $125 per week for 2002 (totaling $6,500) and $115 per week for
2003, except for one week which shows $135 (totaling $6,000).
Petitioner subsequently submitted revised lists which show the
amount of weekly contributions made to Faith Tabernacle Baptist
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