M. Maureen Polsby - Page 9

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          excess charitable contribution deduction from 1991 of $1,921 plus           
          $445 in cash contributions made in 1992).  Although petitioner              
          listed separately the carryover of excess charitable contribution           
          from 1991 and the cash contributions on her Schedule A under                
          Gifts to Charity, for some unexplained reason petitioner did not            
          claim them as a charitable contribution deduction.  At trial,               
          petitioner stated that she is entitled to these deductions and an           
          additional charitable contribution deduction for "possessions",             
          including furniture, that she donated to Goodwill in 1992.                  
               With respect to petitioner's contention that she is entitled           
          to deduct the carryover charitable contribution from 1991, the              
          $445 in cash contributions, and the additional contributions for            
          "possessions" she donated to Goodwill, the record does not                  
          support her claims.  The record does not contain any evidence to            
          establish that she was entitled to a charitable contribution                
          deduction carryover.  In fact, in direct conflict with the                  
          reference to a charitable contribution deduction carryover on her           
          Schedule A, petitioner testified that although she did not                  
          exactly remember, she believed that "this $2366, is what was in             
          my check register or slips I had."  The record does not contain             
          any reliable written records which show the names of donees, the            
          dates of petitioner's alleged contributions, and the amounts that           
          petitioner purportedly donated.  Sec. 1.170A-13(a)(1), Income Tax           
          Regs.  We are not required to accept petitioner's testimony as              





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