- 6 -
years, are good friends. The following handwritten notations
appeared on the check stubs for checks 3597, 3660, 3974, and
4494, respectively: "Tithes/mine", "Donation", "Donation Reim-
bursement", and "Agape Assemblies".
During 1989, petitioner wrote a check to Citizen's Bank
(check to Citizen's Bank) in the amount of $540. The following
handwritten notation appeared on the check stub for that check:
"TFC Deposit/Donation".6
Return Treatment of Claimed Charitable Contributions
In Schedule A of petitioner's 1989, 1990, and 1991 returns,
petitioner claimed deductions for charitable contributions
totaling $22,690, $15,456, and $15,210, respectively.
TFC Engineering
Dona Ana County, New Mexico, issued petitioner a Certificate
of Business Registration for calendar year 1985 for an entity
called TFC Engineering. That certificate stated in pertinent
part:
Whereas, a business registration application form
has been completed on behalf of the above named indi-
vidual, partnership or corporation, and the registra-
tion fee of $25 has been paid;
Now, therefore, the County of Dona Ana, State of
New Mexico, hereby acknowledges receipt of said fee for
the calendar year ending December 31, 1985.
During 1990 and 1991, petitioner provided financial support
6 Checks 3448, 3534, 3597, 3660, 3974, and 4494 and the check to
Citizen's Bank are collectively referred to as the additional
checks.
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