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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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