T.C. Memo. 2006-9
UNITED STATES TAX COURT
BETTY KENDRIX, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2303-04. Filed January 23, 2006.
R disallowed deductions claimed by P, for 2000 and
2001, on account of cash and noncash contributions to
certain churches and charitable organizations. R also
imposed accuracy-related penalties under sec. 6662(a),
I.R.C.
1. Held: Substantial portions of both cash and
noncash contributions claimed by P are disallowed for
failure to comply with the substantiation requirements
of sec. 170(f)(8), I.R.C., and sec. 1.170A-13(b)(2) and
(3), Income Tax Regs.
2. Held, further, R’s imposition of the sec.
6662(a), I.R.C., penalty is sustained.
Betty Kendrix, pro se.
Jonathan Sloat, for respondent.
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