Frank H. and Marla C. Black - Page 13

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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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