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Respondent determined deficiencies in petitioner’s Federal
income taxes of $813 in 2002 and $1,300 in 2003. After
concessions by petitioner,2 the issues for decision are: (1)
Whether petitioner is entitled to deductions on Schedule A,
Itemized Deductions, for cash charitable contributions of $4,500
for 2002 and $1,000 for 2003 and (2) whether petitioner is
entitled to deductions on Schedule A for noncash charitable
contributions of $500 each for 2002 and 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, petitioner
resided in Downingtown, Pennsylvania.
Two computer-generated lists of contributions allegedly made
to The Church of Faith (the church) in Raleigh, North Carolina,
showing contributions of $85 for each week from January 6 to
November 10, 2002, $90 for each of the next 6 weeks, $135 for the
last week of 2002 (totaling $4,500 in 2002), and $20 per week
from January 5 to December 14, 2003 (totaling $1,000 in 2003),
were presented at trial. The lists indicate that each
contribution was made in cash. The lists were prepared by
Chester Muhammad or his daughter and were provided to petitioner
by Mr. Muhammad’s daughter. Mr. Muhammad was petitioner’s
2 Petitioner does not contest a disallowed deduction for a
casualty and theft loss of $4,467 for 2003.
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