- 3 - with respondent’s Appeals Officer Laura M. Gonzalez in Omaha to administratively resolve the cash contribution issues determined in the notice of deficiency and raised by the pleadings. Ms. Gonzalez requested substantiation of the cash contribution deductions claimed on petitioners’ return. In particular, she requested receipts or evidence of payment and information showing that any entity to which a contribution was made was one that qualified under section 501(c)(3).2 Following the exchange of multiple letters between the parties, on January 6, 2006, one of petitioners’ representatives, Attorney Eric Johnson, sent Ms. Gonzalez a letter which, in pertinent part, contained the following: I propose that we settle this case. I think it would be fair for the government to agree that the taxpayers may deduct as a charitable contribution the $74,200 paid to Open Heaven Ministries for tax year 2002. As stated in my letter of August 23, 2005, the itemized list of contributions made by the taxpayers after the Service Center contact totals $223,906, which is somewhat less than the $226,774 reported on the income tax return, and of that $223,906, the taxpayers are unable now to produce substantiation for $1,825, which leaves $222,081 in substantiated contributions. The taxpayers hereby offer to settle this case on the basis that they are entitled to $222,081 of the charitable contribution of $226,774 reported on the return. If you are not satisfied with various aspects of the Open Heaven Ministries issue, we would invite a counter-offer from the government containing a percentage disallowance of the Open Heaven Ministries contribution deduction for 2002 reflecting what the 2 Section references are to the Internal Revenue Code as amended and in effect for the period under consideration.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011