- 2 -
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.
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011