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TODD v. COMMISSIONER

Docket No. 17046-99.

118 T.C. 334 (2002)

118 T.C. No. 19

JOHN C. AND TATE M. TODD, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 19, 2002.

Attorney(s) appearing for the Case

Richard C. Kaufman, for petitioners.

Frederick J. Lockhart, Jr., for respondent.

HALPERN, Judge:

By notice of deficiency dated August 13, 1999 (the notice), respondent determined deficiencies in petitioners' Federal income tax liabilities for petitioners' taxable (calendar) years 1994 through 1997 (the audit years) of $14,181, $61,540, $88,832, and $33,971, respectively. Among the adjustments giving rise to respondent's determination of deficiencies is respondent's disallowance of deductions for charitable contributions petitioners claimed...

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