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dependent for the taxable year but for section 152(a)(9). Sec.
2(b)(3)(B)(i).
We have previously held that petitioner is not entitled to
dependency exemptions for Lynn, Bob, and Robin in 1993 and for
James in 1994. Accordingly, petitioner does not qualify as a
head of household. However, even if we had held that petitioner
is entitled to dependency exemptions under section 152(a)(9),
petitioner would still not qualify, as a matter of law, as a head
of household because of the limitation set forth in section
2(b)(3)(B)(i). Accordingly, we sustain respondent's
determination that petitioner is not entitled to head of
household filing status but rather "single" filing status.
Issue (3): Charitable Contributions - 1993 and 1994
Charitable contributions are deductible under section 170
only if verified under regulations prescribed by the Secretary.
Sec. 170(a)(1). Under the applicable regulations, contributions
of money are required to be substantiated by one of the
following: (1) A canceled check; (2) a receipt from the donee
charitable organization showing the name of the donee, the date,
and amount of the contribution; or (3) in the absence of a
canceled check or receipt, other reliable written records showing
the name of the donee, the date, and amount of the contribution.
Sec. 1.170A-13(a)(1), Income Tax Regs.; see Thorpe v.
Commissioner, T.C. Memo. 1998-123. Contributions of property
other than money are required to be substantiated by a receipt
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