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allowing the exemption. That is insufficient absent proof that
she was a resident of the United States (or of a contiguous
country). Accordingly, the dependency exemption deductions
claimed for both years are not allowed.
B. Deduction for Charitable Contribution to City of Columbus
On Schedule A of his 1976 income tax return, petitioner
claimed a deduction for a charitable contribution of $51,662.62
to the City of Columbus for a house that had been situated on the
lot he purchased in 1975 at 3404 Riverside Drive, Columbus, Ohio,
adjacent to CTC's office building. The house had been rented,
but petitioner decided to give it to the city by moving it across
the road on the other side of the river where it would be used as
a public place. He also gave the city $13,000 for the expense of
moving the house to the park. On December 20, 1976, the City of
Columbus passed an ordinance accepting petitioner's donation of
the single-family stucco house located at 3404 Riverside Drive
and the $13,000 paid to the city as a donation for moving the
house.
The claimed charitable deduction was disallowed by
respondent on the ground that the house was acquired with the
intention to remove or demolish it when it was acquired, and,
consequently, the cost should be considered land acquisition
cost, with the house having no fair market value at the time of
the transfer. Where property is purchased with the intent of
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