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case. The issues for decision are whether petitioner is entitled
to mortgage interest and charitable contribution deductions.
Background
Petitioner is the founder of All Creatures Animal Sanctuary
and Fellowship Church (All Creatures), an organization located in
Hillsboro, Missouri. All Creatures’ mission is to house and
support abandoned and neglected animals. Petitioner, in 2002 and
2005, created All Creatures as a nonprofit corporation, but on
both occasions, the corporation was administratively dissolved
for failure to file an annual report. On January 16, 2007, the
Missouri Secretary of State received a request from petitioner
for reinstatement of nonprofit status for All Creatures. To
finance the sanctuary, petitioner took several mortgages on her
personal residence from multiple banking institutions.
On her 2001 and 2002 Federal income tax returns, petitioner
reported mortgage interest deductions of $42,060 and $39,660,
respectively. Additionally, petitioner reported charitable
contribution deductions in 2001 and 2002 of $37,258 and $29,545,
respectively. On January 11, 2006, respondent issued petitioner
a notice of deficiency relating to 2001 and 2002. Respondent
determined that petitioner did not substantiate the mortgage
interest and charitable contribution deductions.
On April 11, 2006, petitioner, while residing in Florissant,
Missouri, filed her petition with the Court.
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Last modified: November 10, 2007