Gene and Debra Webb v. Commissioner of Internal Revenue

In this frivolous tax appeal case, we affirm the Tax Court and impose sanctions.

In 1982 and 1983, Gene and Debra Webb (the Webbs), residents of Longwood, Florida, reported adjusted gross income and claimed charitable contribution deductions on their federal income tax returns based on contributions to the Universal Life Church, Inc. (ULC). 1 The Tax Commissioner audited the Webbs, disallowed the charitable contribution deductions, and determined income tax deficiencies and additions. The Webbs petitioned the Tax Court to review the Commissioner’s determinations.

The Tax Court sustained the…