Anthony Muhammad - Page 3

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               Respondent determined a deficiency of $6,489 in petitioner’s           
          2003 Federal income tax and an accuracy-related penalty of                  
          $1,297.80 under section 6662(a).  After concessions by both                 
          parties,2 the issues for decision are:  (1) Whether petitioner is           
          entitled to claimed itemized deductions for charitable                      
          contributions totaling $8,500 for 2003 and (2) whether petitioner           
          is liable for the accuracy-related penalty 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.  At the time of filing the petition,                     
          petitioner resided in Philadelphia, Pennsylvania.                           
               Petitioner’s tax return for 2003 was prepared by Chester               
          Muhammad.  On his return, petitioner reported an adjusted gross             
          income of $34,775.  Petitioner deducted charitable contributions            
          totaling $8,500 in 2003.                                                    
               Petitioner had a checking account during 2003.  However,               
          petitioner made no contributions by check and presented no                  
          canceled checks or receipts to establish his alleged                        
          contributions.  Petitioner offered two documents to substantiate            
          the purported contributions at trial.  One is an undated and                


               2 The parties have agreed that the amount disallowed for               
          Schedule C expenses is $5,280, comprising $2,880 for car and                
          truck expenses, $1,600 for depreciation, and $800 for other                 
          expenses.  Petitioner also conceded that he is not entitled to an           
          education credit and that his filing status is single for 2003.             




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