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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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Last modified: May 25, 2011