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FINDINGS OF FACT
Some facts are stipulated and are so found. The stipulation
of facts, with accompanying exhibits, is incorporated herein by
this reference.
At the time the petition was filed, petitioner resided in
Los Angeles, California.
Petitioner’s Returns and Supporting Documentation
2000
Petitioner filed an Internal Revenue Service (IRS) Form
1040, U.S. Individual Income Tax Return, for 2000 (the 2000 filed
return). On line 15 of Schedule A, Itemized Deductions, to that
return she claimed a $12,000 charitable contribution deduction
for “[g]ifts by cash or check” (the cash contributions).
During respondent’s audit of petitioner’s 2000 and 2001
filed returns (the audit), petitioner submitted to the examining
agent an IRS Form 1040X, Amended U.S. Individual Income Tax
Return, for 2000 (the 2000 amended return), which stated that the
Schedule A contribution described in the 2000 filed return “was
incorrectly written as a cash contribution.” On line 16 of the
Schedule A attached to the 2000 amended return, petitioner
claimed a $12,000 charitable contribution deduction for gifts
“[o]ther than by cash or check” (the noncash contributions).
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Last modified: May 25, 2011