Kelvin and Arlene Jackson - Page 5

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          record that petitioners’ allowable medical expenses exceed those            
          conceded by respondent.                                                     
               With respect to the charitable contributions, Ms. Jackson              
          did not present any independent corroboration of her claims,                
          notwithstanding prior advice by respondent’s counsel and by the             
          Court that she do so at the time of trial.  The documents                   
          presented at trial included alleged records of noncash                      
          contributions, but respondent had already conceded the amount               
          claimed on the return for those contributions.  Original records            
          were not produced for any contributions, and it was unclear who             
          had supplied information on certain of the alleged receipts,                
          including Mr. Jackson’s name on some and the payee on others.               
          Certain “receipts” had been altered to increase the dollar                  
          amounts shown.  Even so, amounts shown on the documentation                 
          presented totaled far less than the $3,600 claimed by petitioners           
          on their tax return.  The evidence did not satisfy the                      
          substantiation requirements of section 1.170A-13(a)(1), Income              
          Tax Regs., and does not give us a reliable basis for estimating             
          petitioners’ deductible contributions.                                      
               With respect to petitioners’ belated claim that a portion of           
          the mortgage loan proceeds should be deductible as business                 
          expenses, petitioners have not shown that the amount that they              
          now claim was not previously included and allowed on the                    
          Schedule C that they filed.  Moreover, as respondent argues,                






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