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Respondent determined deficiencies in petitioner’s 2002 and
2003 Federal income taxes of $8,501 and $10,356, respectively,
and accuracy-related penalties under section 6662(a) of $1,700.20
and $2,071.20, respectively. After concessions by respondent,2
the issues for decision are: (1) Whether petitioner is entitled
to claimed itemized deductions for charitable contributions of
$16,500 for 2002 and $20,000 for 2003 and (2) whether petitioner
is liable for accuracy-related penalties pursuant to section
6662(a) as determined by respondent.
Some facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
by this reference. When the petition was filed, petitioner
resided in Downingtown, Pennsylvania. Petitioner has a master’s
degree from Penn State University and is a high school principal.
Petitioner timely filed 2002 and 2003 electronic Federal
income tax returns. Petitioner’s tax returns for the years in
issue were prepared by Mr. Chester Muhammad. On these returns,
petitioner claimed charitable contribution deductions of $16,500
for 2002 and $20,000 for 2003.
2 Petitioner filed his returns as a head of household and
claimed a dependency exemption deduction for his daughter.
Respondent’s notice of deficiency changed petitioner’s filing
status to single and disallowed the dependency exemptions for
both 2002 and 2003. The parties have since stipulated that
petitioner is entitled to head of household filing status and the
dependency exemptions for both years.
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Last modified: May 25, 2011