Stephen D. Ruddel - Page 2

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               Following concessions, we must decide:                                 
               1.  Whether petitioner may deduct certain payments that he             
          made to the Hollywood, Florida, police department as a charitable           
          contribution.  We hold he may not.                                          
               2.  Whether petitioner may deduct those payments as an                 
          expense under section 212 or a portion of these payments as a               
          casualty loss under section 165.  We hold he may not.                       
               3.  Whether petitioner is entitled to a bad debt deduction             
          with respect to two "loans".  We hold he is not.                            
               4.  Whether petitioner is liable for an addition to his 1987           
          tax under section 6651(a)(1).  We hold he is.                               
               Unless otherwise stated, section references are to the                 
          Internal Revenue Code in effect for the year in issue.  Rule                
          references are to the Tax Court Rules of Practice and Procedure.            
          Dollar amounts are rounded to the nearest dollar.                           
                                  FINDINGS OF FACT                                    
               Some facts have been stipulated and are found accordingly.             
          The stipulated facts and exhibits are incorporated herein by this           
          reference.  Petitioner resided in Hollywood, Florida, when he               
          filed his petition.                                                         
               On August 28, 1986, the Hollywood, Florida, police                     
          department (Police Department), with the assistance of the United           
          States Marshals (collectively referred to as Officers), searched            
          petitioner's home pursuant to a valid search warrant. The                   
          Officers found 334 grams of cocaine, $7,362 in United States                




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