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Agape was an organization described in sections 170(c)(2)
and 501(c)(3) and listed in respondent's Publication 78, Cumula-
tive List of Organizations described in Section 170(c) of the
Internal Revenue Code of 1986 (Publication 78).
Ms. Donna Dorris (Ms. Dorris) was the secretary of Agape and
oversaw the work of Ms. Spiegel. Ms. Dorris drew no distinction
between Agape and TFC because she considered both organizations
to be one and the same.
Claimed Charitable Contributions With
Respect to Certain Additional Checks
During 1989, petitioner wrote a check (check 3448) to
Professional Reprographics and a check (check 3534) to R.B.
Design & Printing (R.B. Design & Printing) in the amounts of $86
and $874, respectively. The following handwritten notations
appeared on the check stubs for check 3448 and check 3534,
respectively: "Corrections to Poetry Text" and "Lee Mc's poetry
books". A receipt from R.B. Design & Printing indicated that
check 3534 was used to pay a bill for 500 70-page poetry books,
that a customer named "McWilliams" placed the order for those
books, and that Nathanael Roman received those books.
Petitioner wrote two checks (checks 3597 and 3660) during
1989, one check (check 3974) during 1990, and one check (check
4494) during 1991 to Ms. Shirley A. Ridgway (Ms. Ridgway) in the
amounts of $545, $550, $270, and $70, respectively. Ms. Ridgway
and petitioner, who have known each other for approximately 25
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