Festus E. Obiakor and Paulene Harris Obiakor - Page 3




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          the year in issue, and all Rule references are to the Tax Court             
          Rules of Practice and Procedure.                                            
               Respondent determined a deficiency in petitioners’ Federal             
          income tax for the year 2003 in the amount of $4,283.  The issue            
          for decision is whether petitioners are entitled to claim a                 
          deduction in the amount of $23,211 for noncash charitable                   
          contributions for the taxable year at issue.                                
                                     Background                                       
               The stipulation of facts and the attached exhibits are                 
          incorporated herein by reference.  At the time the petition was             
          filed, petitioner resided in Shorewood, Wisconsin.                          
               Petitioner husband (petitioner) was born and raised in                 
          Nigeria, and immigrated to the United States to attend Texas                
          Christian University.  After college, he received two master’s              
          degrees and a doctorate in education.  He is employed with the              
          University of Wisconsin as a Professor of Education.                        
               Petitioner was raised in a religious community in Nigeria              
          that emphasized charitable giving.  As part of his religious                
          beliefs, petitioner gives amounts of cash and noncash items to              
          various churches and charitable organizations.                              
               During the taxable year in issue, petitioners purportedly              
          made charitable contributions to St. Jude’s Hospital, Texas                 
          Christian University, their church, and the Salvation Army.                 
          Among the items that petitioners gave to the Salvation Army were:           







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