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deficiency, respondent listed three adjustments to petitioners'
itemized deductions, disallowing $13,847 of those deductions. As
to petitioners' deduction for charitable contributions in the
amount of $18,496, respondent concluded that petitioners had not
established that they donated any amount greater than $16,536 to
qualifying organizations during the tax year and, therefore,
reduced petitioners' deduction by $1,960. At trial, petitioners
provided no evidence or testimony substantiating the additional
$1,960 in charitable contributions. Consequently, as there is no
rational basis to approximate those contributions, we conclude
that petitioners have not met their burden of substantiating
them.
As to petitioners' line 21 deduction for "Job Expenses and
Most Other Miscellaneous Deductions" in the amount of $10,810,
respondent conceded that petitioners were entitled to deduct $161
for other miscellaneous itemized deductions (line 20 deduction).
Respondent, however, concluded that petitioners had not
established that they paid any amount greater than $560 for the
unreimbursed employee expenses related to Mr. Brown's job as a
minister (line 19 deduction) and, accordingly, disallowed $10,089
of those expenses. On the basis of the increase in petitioners'
gross income resulting from all of the adjustments in the notice
of deficiency, however, respondent determined that the allowable
miscellaneous expenses in the amount of $721 were less than 2
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