Pepi Schafler, f.k.a. Pepi Summer - Page 12

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               Petitioner has failed to offer evidence concerning the                 
          medical treatment underlying the expenses remaining in issue.               
          Petitioner, therefore, has failed to meet her burden of proof               
          with respect to the remaining expenses, and we sustain                      
          respondent's determination to that extent.                                  
               4.  Charitable Contributions                                           
               On her return, petitioner claimed a deduction for charitable           
          contributions in the amount of $2,260.  The return reflects cash            
          contributions in the amount of $890 and contributions other than            
          cash in the amount of $1,370.  Petitioner submitted a list,                 
          prepared before her examination by respondent's agent, of the               
          charitable contributions which she purportedly made during the              
          taxable year.  The total amount reflected on this list, $2,936,             
          exceeds by $676 the amount claimed on her return.5  To                      
          substantiate the deductions claimed, petitioner submitted                   
          canceled checks, letters from charitable organizations, and notes           
          prepared before trial consisting of her estimation of the fair              
          market value of donated property; however, these materials relate           
          to only a portion of the deductions claimed.  Respondent has                
          allowed petitioner to deduct cash contributions in the amount of            
          $145 and noncash contributions in the amount of $495.                       
          Petitioner's claimed contributions, as reflected by her list and            
          by other items in the record, are as follows:                               

          5  Although petitioner's list indicates a total of $2,926,                  
          the sum of the items listed is $2,936.                                      



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