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deposited into the TFC account in the name of a company about
which the record discloses almost nothing. We are not convinced
that the blank checks were "to or for the use" of Agape. Davis
v. Commissioner, supra. Petitioners also claim some carbon
copies of blank checks are proof of other 1991 contributions to
Agape, and for 1992, petitioners only have carbon copies of blank
checks, which for the same reasons are not proof of
contributions. We also note that even though we cannot rely on
petitioners' alleged evidence, our computation of the amounts of
canceled blank checks and blank carbon copies for 1991 ($7,105)
and of the blank carbon copies for 1992 ($8,438) totals far less
than the amounts of $16,176.48 and $17,940.00 claimed as
contributions on petitioners' 1991 and 1992 returns,
respectively.
At trial, we had reservations about Ms. Spiegel's testimony.
With respect to donation ledgers, she stated that she wrote the
numbers "On the date I received the money." Yet examination of
these ledgers show they do not comport with the dates of the
alleged contributions made on a number of occasions. Ms.
Spiegel's testimony about cash contributions by petitioners was
unsatisfactory.
The amounts petitioners claimed as charitable contributions
to Agape in their returns for 1991 and 1992 are greater than the
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