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Ladish during the years at issue until June 1992 as a
stenographer. She was classified by her employer as a Steno III,
having progressed from Steno I and Steno II. Her work was
entirely administrative, and, at some point, in addition to her
work as stenographer, she became manager of the company store
that stocked gifts and other paraphernalia bearing the Ladish
logo. Mrs. Zeidler's employment with Ladish terminated in June
1992 after 18 years of service. She was terminated because of
adverse business and economic conditions facing Ladish. For
several years prior to 1992, Ladish had been faced with such
problems and had, over the years, laid off or terminated
employees, beginning with employees having less seniority.
On their Federal income tax returns for 1990, 1991, and
1992, petitioners claimed charitable contribution deductions of
$141, $211, and $143, respectively, for contributions to an
organization in Greendale, Wisconsin, known as the Cantare
Chorale singers (the organization).3 The organization at one
3
The charitable contribution adjustments in the notices of
deficiency were $183, $418, and $143, respectively, for 1990,
1991, and 1992. At trial, the parties advised the Court that the
adjustments in the notices of deficiency involved other charities
as well as the contributions to the Cantare Chorale singers but
that the parties had reached a basis for settlement of the
adjustments involving the other charities. The deductions to the
Cantare Chorale singers represented the only remaining issue for
trial, those amounts being $141, $211, and $143, respectively,
for the 3 years at issue. The Court further notes that, in the
stipulation of facts filed with the Court, the charitable
contribution adjustment relating to the Cantare Chorale singers
(continued...)
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