Nathanael Roman - Page 18

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          Reimbursement", and "Agape Assemblies".  As we understand peti-             
          tioner's position, he claims that he wrote those checks in order            
          to reimburse Ms. Ridgway for contributions that she made on his             
          behalf to Agape during 1989, 1990, and 1991.  We do not have an             
          explanation from Ms. Ridgway, who testified with respect to                 
          another issue in this case, about the purposes of those checks,             
          nor do we know if she deducted in her returns the funds that                
          petitioner claims she contributed to Agape on his behalf.                   
               With respect to the check to Citizen's Bank, the following             
          handwritten notation appeared on that check:  "TFC Deposit/                 
          Donation".  Even petitioner's own notation suggests that peti-              
          tioner made a deposit to a bank account of TFC, and not Agape, at           
          Citizen's Bank.                                                             
               On the instant record, we find that petitioner has failed to           
          carry his burden of showing that the additional checks (i.e.,               
          checks 3448, 3534, 3597, 3660, 3974, and 4494 and the check to              
          Citizen's Bank) represent amounts that petitioner contributed               
          during 1989, 1990, and/or 1991 to or for the use of Agape within            
          the meaning of section 170(c).                                              
               Summary                                                                
               Based on the entire record before us, we find that peti-               
          tioner has failed to carry his burden of proving that the amounts           
          of the blank checks and the additional checks (as well as any               
          cash) that he claims he contributed to or for the use of Agape              
          during 1989, 1990, and/or 1991 were, in fact, contributed during            




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