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has phrased many of these arguments generally, without reference
to specific deductions. We have considered these arguments with
regard to each deduction, but in the interest of brevity have
also chosen to speak generally whenever possible.
With respect to his charitable activities, petitioner
maintained fairly detailed records of his expenditures. While
traveling, petitioner collected receipts from each of his
expenditures and placed them in an envelope. If petitioner was
unable to obtain a receipt for an expenditure, he made a
contemporaneous notation of the expenditure. Upon returning from
a trip, petitioner would put the envelope containing the receipts
for that trip in a file marked with the name of the charitable
organization to which the trip related. This system ensured that
the name of the organization, the date (at least to within a few
days), and the amount of each expenditure was recorded.
Accordingly, we conclude, with the exception of items
specifically mentioned below, petitioner has substantiated his
charitable contribution deductions. In light of this conclusion,
and the volume of transactions at issue, we shall only address
those contentions about which there appears to be a genuine
dispute, and we hold for petitioner with respect to any of the
disputed deductions not specifically mentioned herein.
Respondent asserts that petitioner deducted several
expenditures twice. Specifically, respondent asserts that an
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