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Revenue Code in effect for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in petitioners’ 2002 and
2003 Federal income taxes of $2,928 and $2,139, respectively.
After concessions,1 the issue for decision is whether petitioners
are entitled to charitable contribution deductions.
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits, as well as an
additional exhibit introduced at trial, are incorporated herein
by this reference. At the time the petition was filed,
petitioners resided in Clarksville, Maryland.
Petitioners timely filed joint 2002 and 2003 Federal income
tax returns. On their 2002 return, petitioners reported adjusted
gross income of $79,864 and claimed a $20,900 deduction for cash
contributions. On their 2003 return, petitioners reported
adjusted gross income of $72,937 and claimed a $20,511 deduction
for cash contributions.2 Respondent issued petitioners a notice
of deficiency in September 2005 disallowing $19,400 of the
deductions claimed for 2002 and $19,011 of the deductions claimed
1 For 2002, respondent concedes that petitioners are
entitled to expense deductions claimed on Schedule E,
Supplemental Income and Loss.
2 Petitioners also claimed $2,650 in noncash contributions
on their 2003 return. Respondent allowed this noncash
contribution deduction, and therefore it is not at issue.
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Last modified: November 10, 2007