NEIL v. COMMISSIONER

Docket No. 26310-83.

50 T.C.M. 1254 (1985)

T.C. Memo. 1985-520

Garnett W. and Dorothy M. Neil v. Commissioner.

United States Tax Court.

Filed October 2, 1985.


Attorney(s) appearing for the Case

Garnett W. Neil and Dorothy M. Neil, pro se, San Diego, Calif. Miles D. Friedman, for the respondent.


Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent determined deficiencies in petitioners' Federal income tax and additions to tax as follows:

                            Addition to Tax
   Year       Deficiency     Sec. 6653(a)1

   1980 ....    $3,344         $172.15
   1981 ....     3,413          170.65

The issues for our decision are: (1) whether petitioners are entitled to a charitable...

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