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he purchased his morning coffee. Petitioner has failed to
convince us that he made a charitable contribution in cash of
$3,175, or, indeed, that he made any charitable contributions of
cash, during 1987. Petitioner has failed to carry his burden of
proof on this issue, and we sustain so much of respondent’s
determination as relates thereto.
2. 1988
a. Contribution
In her notice of deficiency, respondent included an
adjustment disallowing a charitable contribution deduction in the
amount of $2,760. That amount is reflected as a cash
contribution on Schedule A, Itemized Deductions, attached to
petitioner’s Form 1040, U.S. Individual Income Tax Return 1988.
Petitioner’s testimony with respect to cash contributions was the
same for 1988 as it was for 1987. Petitioner has failed to
convince us that he made a charitable contribution in cash of
$2,760, or, indeed, that he made any charitable contributions of
cash during 1988 beyond what, already, has been allowed by
respondent. Petitioner has failed to carry his burden of proof
on this issue, and we sustain so much of respondent’s
determination as relates thereto.
b. Miscellaneous Deductions
In her notice of deficiency, respondent included an
adjustment disallowing a miscellaneous deduction in the amount of
$2,760. Petitioner testified that, during his employment at
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