Frank H. and Marla C. Black - Page 28
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After examination, respondent disallowed these deductions in
full. Petitioners ultimately agreed to the disallowance of all
claimed ULC deductions.
Likewise, petitioners claimed charitable deductions on their
1987, 1988, and 1989 joint tax returns of $22,350, $13,125, and
$13,250, respectively for contributions to NFBC. After
examination, respondent disallowed the NFBC deductions in full.
Petitioners ultimately agreed to the disallowance of all claimed
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 NFBC was a church. Agent Helton tried, without
success, to verify the existence of NFBC through other means.
Agent Helton checked the telephone listing for Rock Hill, S.C.,
and also checked the IRS’s official listing of approved section
501(c)(3) organizations, but found no listings for the alleged
Because the statement provided by Mr. Black included “Inc.”
in the alleged church’s name, Agent Helton checked with the
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Last modified: March 27, 2008