Betty Kendrix - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               HALPERN, Judge:  By notice of deficiency dated November 4,             
          2003 (the Notice), respondent determined deficiencies in                    
          petitioner’s Federal income tax liabilities of $2,114 and $2,499            
          for her taxable (calendar) years 2000 and 2001 (the audit years),           
          respectively, and accuracy-related penalties of $422.80 and                 
          $499.80 for 2000 and 2001, respectively.  At the trial of this              
          case, petitioner conceded respondent’s denial, for lack of                  
          substantiation, of her reported capital loss of $1,733 and                  
          respondent’s application of the 10-percent additional tax under             
          section 72(t), in the sum of $849, on a premature distribution              
          from her individual retirement account.  On brief, respondent               
          concedes a 2001 cash contribution by petitioner of $713.  The               
          issues for decision are (1) whether petitioner is entitled to               
          certain charitable contribution deductions for the audit years              
          and (2) whether petitioner is liable for the accuracy-related               
          penalties determined by respondent under section 6662(a).                   
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the audit years, and all            
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.  All dollar amounts have been rounded to the nearest             
          dollar.                                                                     








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