The stuff of this blog is controversy, specifically tax controversy. United States Tax Court is one great squared circle, where IRS and petitioners (and some bystanders, innocent or not) batter away at each other. The judges and STJs referee, as the Ch J disqualifies whichever petitioner fails to make weight.

Peering into this scrum are we of the blogosphere, the trade press, and solos, even such as I, a “general practitioner of very limited experience and mediocre qualifications.” Our quarry is the interesting, novel, offbeat beating-up or beating-down of one side or the other.

But so rare as to be unaccountable is a case like Deborah Gail Martin, Docket No. 7429-22, filed 5/23/24. Deborah has a Section 170 SNOD, but she isn’t a Dixieland Boondocker or a false façader. Deborah is a loyal congregant of “United House of Prayer for All People, a church described in section 170(c).” Transcript, at p. 4.

Judge Albert G. (“Scholar Al”) Lauber says she “has contributed extremely generously to the Church for many years, making gifts that represent a very substantial portion of her relatively modest income.” Idem, as my highly-experienced, highly-qualified, and expensive colleagues say.

Deborah has CWAs for better than $17K of the $36K she claimed on her 1040 for year at issue. Besides, she has bank statements for cash contributions less than $250 for another $600. The SNOD she got acknowledged $19K, but disallowed the rest. Apparently Deborah’s AGI was below the phase-out for Sched As.

Time for trial testimony.

“Petitioner originally believed that her bank records would show contributions to the Church for [year at issue] that were larger than this amount. However, when the case was called for trial… petitioner agreed that she had made some mistakes in calculating her deduction, and that her bank records did not in fact support a deduction larger than the IRS had allowed. She confirmed her agreement that the amount allowed by the IRS was correct and that she had no evidence to substantiate a larger deduction.” Transcript, at p. 7.

IRS never imposed chops.

Brings a smile to my wrinkled old face to see a Psalm 133:1 finish to a Tax Court off-the-bencher.