- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011