- 2 - the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined a deficiency in petitioners’ Federal income tax for the year 2003 in the amount of $4,283. The issue for decision is whether petitioners are entitled to claim a deduction in the amount of $23,211 for noncash charitable contributions for the taxable year at issue. Background The stipulation of facts and the attached exhibits are incorporated herein by reference. At the time the petition was filed, petitioner resided in Shorewood, Wisconsin. Petitioner husband (petitioner) was born and raised in Nigeria, and immigrated to the United States to attend Texas Christian University. After college, he received two master’s degrees and a doctorate in education. He is employed with the University of Wisconsin as a Professor of Education. Petitioner was raised in a religious community in Nigeria that emphasized charitable giving. As part of his religious beliefs, petitioner gives amounts of cash and noncash items to various churches and charitable organizations. During the taxable year in issue, petitioners purportedly made charitable contributions to St. Jude’s Hospital, Texas Christian University, their church, and the Salvation Army. Among the items that petitioners gave to the Salvation Army were:Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007