Betty Kendrix - Page 9

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          Angeles Church receipt and 2001 Gospel Temple Baptist Church                
          receipt is more than the $4,598 in cash contributions claimed on            
          the Schedules A attached to the 2001 filed and amended returns.             
          Petitioner’s Voluntary Bankruptcy Petition                                  
               On July 28, 1998, petitioner filed a voluntary petition for            
          relief under chapter 7 of the Bankruptcy Code with the U.S.                 
          Bankruptcy Court for the Central District of California (the                
          bankruptcy petition).  The bankruptcy petition lists total assets           
          of $4,100 and total liabilities of $118,847 for petitioner.  The            
          bankruptcy petition also lists petitioner’s monthly charitable              
          contributions as zero.                                                      
          Petitioner’s 1998 and 1999 Charitable Contribution Deductions               
               On Schedule A attached to both her 1998 and 1999 Federal               
          income tax returns, petitioner claimed $15,000 in cash                      
          contributions.                                                              
          Petitioner’s Employment by the IRS                                          
               Petitioner was employed by the IRS for more than 30 years.             
          She was employed by the IRS’s Criminal Investigation Division               
          from 1971 through 1982 and as a revenue officer from 1982 through           
          2004.                                                                       
                                       OPINION                                        
          I.  Burden of Proof                                                         
               Generally, petitioner bears the burden of proof.  See Rule             
          142(a)(1).  Section 7491(a) may shift the burden to the                     






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Last modified: May 25, 2011