- 9 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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