- 2 - is not reviewable by any other court, and this opinion shall not be treated as precedent for any other case. Respondent determined a deficiency in petitioner’s Federal income tax for the 2003 taxable year in the amount of $3,592. The issues now before the Court are: (1) Whether petitioners are entitled to an itemized deduction of $2,096 for charitable contributions of cash to First Presbyterian Church in Chattanooga, Tennessee (church);2 (2) whether petitioners are entitled to an itemized deduction in excess of the $25 respondent allowed for their charitable contribution of property to the Salvation Army; and (3) whether petitioners are entitled to a miscellaneous itemized deduction of $21,729 for unreimbursed employee expenses. 2 Respondent concedes that petitioners are allowed a $500 deduction for 20 separate $25 contributions made to their church in 2003 by check through the use of tithing envelopes. On their 2003 Federal income tax return, petitioners claimed only a $2,000 deduction for contributions to their church in cash rather than by check. At trial, petitioners claimed such cash contributions in the amount of $2,096, as set forth on a self-prepared itemized schedule they prepared for trial. That schedule showed cash contributions by week to “Lee Anderson’s Class”; “Children’s Class”; and “Church Offering”. The totals for 2003 were $84, $85 (but petitioners claimed $87 as the result of an addition error), and $1,925, respectively. The weekly donations to each of the two “classes” were $2 with one exception, a $1 donation to the “Children’s Class” for the week of June 22. Respondent also concedes that petitioners are entitled to a $250 deduction for contributions made to the Lookout Mountain Education Fund in 2003. That deduction was not allowed in the statutory notice of deficiency that was issued by respondent in this case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: November 10, 2007