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NFBC deductions, and petitioners subsequently conceded, pursuant
to settlement, that no NFBC deductions were allowable.
During the examination, Mr. Black gave Agent Helton a
statement which he stated should be sufficient to verify the
deductions claimed for contributions to NFBC. The statement
provided by Mr. Black included both the name of the alleged
church, listed as “New Faith Baptist, Inc.” and the amounts of
the alleged charitable contributions. Petitioners never provided
any evidence to Agent Helton to show that any church named NFBC
actually existed. Agent Helton tried, without success, to verify
the existence of NFBC through other means. Agent Helton checked
the telephone listing for Rock Hill, South Carolina, and also
checked the IRS’s official listing of approved section 501(c)(3)
organizations, but found no listings for the alleged church.
Because the statement provided by Mr. Black included “Inc.”
in the alleged church’s name, Agent Helton checked with the South
Carolina Secretary of State (SCSOS). Agent Helton learned from
the SCSOS that a corporation named New Faith Baptist, Inc., was
on file with the SCSOS, and that its articles of incorporation
listed petitioners’ Rock Hill, South Carolina, address as its
corporate address, and listed Mr. Black as a corporate officer.
During a January 28, 1991, telephone conversation, Mr. Black told
Agent Helton that NFBC had moved to Hickory, North Carolina.
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