- 2 - 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.Page: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007