Betty Kendrix - Page 15

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          nondeductible.  See Castleton v. Commissioner, T.C. Memo. 2005-58           
          (deduction for contribution of property to allegedly tax-exempt             
          religious organization alternatively denied for failure of the              
          organization to issue a receipt satisfying the requirements of              
          section 170(f)(8)(B)(ii)); see also Roark v. Commissioner, T.C.             
          Memo. 2004-271.  Only the $125 contribution for “Annual Choir               
          Concert” is not subject to section 170(f)(8).  Respondent does              
          not otherwise challenge the 2000 or 2001 Gospel Temple Baptist              
          Church receipts as evidencing petitioner’s payment of the amounts           
          listed therein or the status of that church as an organization              
          described in section 170(c).  Therefore, we hold that, for 2000,            
          petitioner is entitled to deduct $125 on account of cash                    
          contributed to Gospel Temple Baptist Church for “Annual Choir               
          Concert”.                                                                   
                    2.  2001                                                          
               On brief, petitioner claims to have provided documentation             
          sufficient to support a deduction for 2001 cash contributions of            
          $4,133 consisting of $713 in donations to West Angeles Church of            
          God in Christ and $3,400 in donations to Gospel Temple Baptist              
          Church.                                                                     
               Respondent concedes that the 2001 West Angeles Church                  
          receipt “satisfies the requirements of [section 170(a)]”.                   
          Accordingly, respondent concedes petitioner’s entitlement to a              
          $713 deduction for 2001 cash contributions to that church.                  






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