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determined that this amount was paid for State sales taxes and
disallowed the deduction in full on the grounds that State sales
taxes are not deductible.
Prior to 1986, section 164(a)(4) allowed a deduction for
State and local general sales taxes paid or accrued within the
taxable year. Section 164(a)(4) was repealed by section
134(a)(1) of The Tax Reform Act of 1986, Pub. L. 99-514, 100
Stat. 2116. Petitioners offered no evidence that the $1,964 they
deducted for "other taxes" represented anything other than State
sales taxes. In fact, petitioners state in their posttrial
memorandum that the "other taxes" were State sales taxes on
personal property. Respondent is sustained on this issue.
6. Charitable Contributions
On their 1990 Schedule A, Form 1040, petitioners claimed
charitable contributions in the amount of $4,342. Respondent
disallowed $126 of this amount for lack of substantiation.
Section 170 allows a deduction for charitable contributions
subject to certain limitations. If a taxpayer makes a cash
contribution, the taxpayer in the absence of a canceled check or
receipt from the donee must maintain other reliable written
records showing the name of each charity, and the date and the
amount of each contribution. Sec. 1.170A-13(a)(1)(iii), Income
Tax Regs.
Petitioners offered no evidence to substantiate their
charitable contributions apart from the photocopies of hundreds
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