- 18 - 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 duringPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
Last modified: May 25, 2011