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At the time the petition was filed, petitioner lived in Las
Cruces, New Mexico.
Petitioner, who was an engineer working for the Department
of the Army during the years at issue, filed returns for 1989,
1990, and 1991 on February 21, 1992, October 12, 1993, and
February 5, 1992, respectively.
Claimed Charitable Contributions
Claimed Charitable Contributions
With Respect to Certain Blank Checks
During 1989, 1990, and 1991, petitioner prepared checks
totaling $15,092,5 $14,100, and $12,695, respectively, on which
he left the payee lines blank (blank checks) at the request of
one or more individuals whose identity is not disclosed in the
record. One of the following or similar handwritten notations
appeared on the check stubs (check stubs) for those checks:
"Donation", "Lee's Travel Fund & Meals", "Lee's Travel Fund",
"Contribution", and "Charitable Donation". The blank checks were
deposited into a bank account (TFC account) of Twenty-First
Century Corporation (TFC) by Ms. Thelma Spiegel (Ms. Spiegel).
Ms. Spiegel, inter alia, served as the bookkeeper for the collec-
tion of tithes and charitable contributions of Agape Assemblies,
Inc. (Agape) and Body of Christ Church and had the authority to
make deposits to, and withdrawals from, the TFC account.
5 Hereinafter, all dollar amounts are rounded to the nearest
dollar.
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