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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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