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under penalty of perjury, that (as of July 27, 1998) she owned
$4,100 in total assets and that her current (monthly) expenses
did not include any charitable contributions. Respondent also
points to a deposition taken of petitioner (on January 6, 1999),
in connection with the bankruptcy proceeding, in which she states
that one of her creditors had seized all of her property. In
addition, respondent argues that “[p]etitioner’s numerous
inconsistent [reporting] positions further undermine her
credibility.”
Petitioner has failed to corroborate her testimony regarding
the manner in which she acquired the allegedly donated items.
Nor has she offered any proof in support of her claims regarding
the costs (together with dates of acquisition) of those items as
reflected in her worksheets, which, if supported, might give some
indication of the values of those items. Nonetheless, the
receipts from Goodwill Industries, L.A. Family Housing, and the
Salvation Army are evidence that those organizations did, in
fact, receive some amount of used clothing, appliances,
furniture, etc., from petitioner. Respondent does not challenge
the authenticity of those receipts, nor does he question the
status of those organizations as organizations described in
section 170(c), and we find that petitioner delivered the items
listed in those receipts to those organizations.
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