- 15 -
Agape. If he did, he is entitled to deduct those contributed
amounts under section 170(a).
To support his position, petitioner introduced into evidence
(1) check stubs containing, inter alia, the information that ap-
peared on the blank checks and the additional checks;9 (2) lists
that he prepared for each of the years at issue (petitioner's
lists) of the blank checks and the additional checks, as well as
of the cash, that he claims he contributed to or for the use of
Agape during each such year; and (3) the testimony of Ms. Spiegel
and Ms. Dorris.
We are unwilling to rely on (1) the check stubs for the
blank checks because petitioner left blank the payee lines on the
checks represented by those stubs10 and those checks were depos-
ited into the bank account of TFC11 and (2) petitioner's lists
because they are nothing more than petitioner's self-serving,
uncorroborated statements.
9 Respondent does not dispute that the handwritten notations on
the check stubs for the checks that petitioner wrote during the
years at issue appeared on those checks. Hereinafter, for ease
of reference, we shall discuss the handwritten notations on the
check stubs that are in evidence as if they appeared on the
checks to which those stubs relate.
10 Ms. Dorris testified that it was the policy of Agape that the
payee lines on those checks be left blank. She did not explain
the reason for that alleged policy.
11 Petitioner does not dispute that during the years at issue
TFC was not an organization described in secs. 170(c)(2) and
501(c)(3) and that it was not listed in Publication 78. There-
fore, we conclude that he does not dispute that contributions
made to or for the use of TFC during those years are not deduct-
ible under sec. 170(a).
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