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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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