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Tax Court Rules of Practice and Procedure. The decision to be
entered is not reviewable by any other court, and this opinion
should not be cited as authority.
Petitioner, whose adjusted gross income for 2002 was less
than $115,000, claimed a $55,764 charitable contribution
deduction on her 2002 Federal income tax return. As a result of
the disallowance of that deduction, respondent determined a
$14,6491 deficiency in petitioner’s 2002 Federal income tax and
imposed a $2,930 accuracy-related penalty pursuant to section
6662(a).
The issues in dispute are as follows: (1) Whether
petitioner is entitled to a charitable contribution deduction in
excess of the amount now allowed by respondent and (2) whether
the underpayment of tax required to be shown on petitioner’s 2002
Federal income tax return is due to negligence or intentional
disregard of rules or regulations.
Background
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioner resided in New York,
New York.
1 Dollar amounts are rounded.
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