Darin Warfield and Sharon Hardin - Page 3

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               Respondent determined deficiencies of $2,772 for 2002 and              
          $4,499 for 2003, and an accuracy-related penalty under section              
          6662(a) of $899.80 for 2003.  After concessions by the parties,2            
          the issues for decision are:  (1) Whether petitioners are                   
          entitled to deduct $1,790 and $9,040 in cash charitable                     
          contributions on their 2002 and 2003 returns, respectively;3 (2)            
          whether petitioners are entitled to deduct a $500 noncash                   
          charitable contribution on each of their 2002 and 2003 returns;             
          and (3) whether petitioners are liable for the section 6662(a)              
          accuracy-related penalty for 2003.                                          
               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, petitioners                
          resided in Coatesville, Pennsylvania.                                       





               2 Respondent disallowed deductions for student loan interest           
          in 2002 and 2003 but has since conceded those deductions.                   
          Respondent disallowed an education credit of $1,500 for 2002 and            
          $1,164 for 2003.  Petitioners stipulated that they did not have             
          any qualified higher education expenses in 2002 or 2003.                    
          Respondent determined unreported pension or annuity income of               
          $2,015 for 2003 but was unable to verify these amounts from the             
          third parties and conceded that issue.                                      
               3 Respondent originally disallowed petitioner’s entire                 
          deductions for cash charitable contributions of $7,100 in 2002              
          and $15,000 for 2003, but respondent and Sharon Hardin have                 
          stipulated that Ms. Hardin made $5,310 and $5,960 in charitable             
          contributions to Hutchinson Memorial U.A.M.E. Church in 2002 and            
          2003, respectively.                                                         




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