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In connection with this litigation, petitioner furnished a
receipt for taxable year 2000 cash contributions to “Gospel
Temple Baptist Church Partners Program” (the 2000 Gospel Temple
Baptist Church receipt), dated February 10, 2000,1 which lists a
total of $6,655 in contributions for 2000 and is signed by both
the church pastor and secretary. That contribution was not
listed on Schedule A to the 2000 amended return. The 2000 Gospel
Temple Baptist Church receipt breaks down the total contribution
into 12 monthly contributions ranging from $250 to $450. It also
lists specific payments for “Church Anniversary”, “Revival”,
“Annual Choir Concert”, “Pastor’s Appreciation”, and “Building
Fund” in amounts ranging from $125 (for “Annual Choir Concert”)
to $1,200 (for “Building Fund”).
2001
Petitioner filed an IRS Form 1040 for 2001 (the 2001 filed
return). On line 15 of Schedule A she claimed a $4,598 deduction
for cash contributions and, on line 16, a $4,000 deduction for
noncash contributions. The IRS Form 8283 attached to that return
lists a single noncash contribution to “Goodwill Ind. Los
Angeles, CA” of “clothing, furniture, misc items” valued at
1 As discussed infra, petitioner also furnished a receipt
for 2001 contributions to the same church dated Feb. 12, 2002.
We assume that the receipt for 2000 contributions was
inadvertently misdated, and that the writer meant to enter Feb.
10, 2001, as the date of execution of the receipt.
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