- 17 -
for the use of that organization within the meaning of section
170(c).
With respect to check 3448 in the amount of $86, the follow-
ing handwritten notation appeared on that check: "Corrections to
Poetry Text". There is no reliable evidence in the record that
"Corrections to Poetry Text" was related to a project of Agape.
With respect to check 3534 in the amount of $874 that was
payable to R.B. Design & Printing, the following handwritten
notation appeared on that check: "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. Ms. Dorris testified that
Mr. McWilliams was one of the "members of the ministry". Assum-
ing arguendo that Mr. McWilliams were a member of the ministry of
Agape,12 the record does not disclose whether he was acting in
that capacity when he incurred the expense at R.B. Design &
Printing that petitioner paid with check 3534.
With respect to checks 3597, 3660, 3974, and 4494 in the
respective amounts of $545, $550, $270, and $70 that were payable
to Ms. Ridgway, the following handwritten notations appeared on
those respective checks: "Tithes/mine", "Donation", "Donation
12 In her testimony, Ms. Spiegel referred to Body of Christ
Church. Except for its name, which suggests that Body of Christ
Church may have had a ministry, the record discloses no facts
about that organization.
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