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entitled to a deduction in excess of the amount allowed by
respondent. We, therefore, sustain respondent's determination
insofar as it relates to those items.
With respect to petitioner's claimed charitable
contributions in cash or by check, it is not entirely clear from
the record which items serve as the basis of respondent's
allowance. Two items, purported donations to the University of
Buffalo School of Architecture and Planning and to the March of
Dimes, are not substantiated by a check or letter from the donee
which reflects the amount of the donation; therefore, petitioner
has failed to meet her burden of proof with respect to those
items. Rule 142(a). Moreover, petitioner has not proven that
the following payees indicated on checks and credit card receipts
reflected in the record were qualified donees for purposes of
section 170(c): Jewish Review, Amherst Police Club, Buffalo
Museum of Science, NCCL, and the Greater Buffalo Chamber of
Commerce. Petitioner, therefore, is not entitled to a deduction
with regard to those items. Although petitioner has met her
burden of proof with respect to the remaining items in dispute,
the total amounts reflected on those checks do not exceed the
amount allowed by respondent. Accordingly, we sustain
respondent's determination on this issue to that extent.
5. Addition to Tax Under Section 6651(a)
We now address respondent's determination that petitioner is
liable for the addition to tax under section 6651(a) for failure
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