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motive for 1992 and 1993. Petitioner did not have any knowledge
of the value of timber in place or whether his claimed losses had
any relevance to the amount of gain he might have earned from
their harvest. Petitioner’s focus was on developing a tree farm
for his children or the next generation. Petitioners did not
produce any documentary evidence supporting the deductions
claimed on their Schedules F.
Petitioners, in connection with their professional
employment as teachers, paid union dues and purchased equipment
and teaching aids. Petitioners claimed employee business
expenses on Schedule A of their 1992 and 1993 returns in the
respective amounts of $3,691.42 and $4,605. At trial,
petitioners offered documentary evidence which corroborated
amounts that were substantially less than those claimed on their
1992 and 1993 returns.
Petitioners claimed contributions to charity by cash or
check in 1991, 1992, and 1993 in the respective amounts of
$3,530, $3,470, and $3,160. At trial, petitioners presented
documentary evidence substantiating $10 and $25 of contributions
for 1992 and 1993, respectively, and no documentary evidence was
presented for 1991. Petitioner contended that he and his wife
tithed at a 10-percent rate during the years in question, which
would have resulted in contributions of $8,000 in each year under
consideration. He offered the explanation that he claimed only
about $3,000 in each year because larger claims might have
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