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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.
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