Richard Walter Drake - Page 13

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          Respondent contends that petitioner has failed to establish that            
          he made any contributions or that he paid any additional expenses           
          during the year.                                                            
               Section 170 allows a deduction for any charitable                      
          contributions made during the taxable year.  Petitioner testified           
          that he made cash donations in the amount of $25 each month to              
          the Episcopal church he attended, but provided no other evidence            
          to substantiate this amount.  We find that petitioner is entitled           
          to a deduction for charitable contributions in the amount of                
          $150.  See Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930).               
               Petitioner contends that he paid deductible unreimbursed               
          employee business expenses during the year in issue.  Petitioner            
          testified that he paid $211 for luggage which he was required to            
          purchase as a flight attendant.  Petitioner also testified that             
          he paid amounts for meals in excess of the amounts reimbursed by            
          Delta.  Petitioner did not present any other evidence to                    
          substantiate these expenses.  Petitioner has not convinced us               
          that these amounts were paid in the year in issue.                          
               Petitioner also contends that he paid $519 for new uniforms            
          he purchased as a Delta employee.  Petitioner presented copies of           
          his "Employee's accounts receivable statement" issued by Delta in           
          an attempt to substantiate this amount.  The first statement is             
          dated September 15, 1992, and reflects a previous balance of $517           
          and new charges of $117 for uniforms and accessories.  Thus, the            






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