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on her 1993 and 1994 Schedules C for her wholesale activity.
Therefore, in 1994 petitioner is not entitled to expenses in
excess of the $326 for advertising expense and those expenses
allowed by respondent in the notice of deficiency.
Petitioner claimed itemized charitable deductions in the
amounts of $6,472 and $6,813 for the taxable years 1993 and 1994,
respectively. Respondent disallowed the expenses in the notices
of deficiency. As previously indicated, respondent has conceded
a large percentage of these deductions. Respondent contends that
any additional amounts of contributions were not properly
substantiated. Petitioner now asserts she is entitled to deduct
additional amounts not reported on her 1993 Federal income tax
return for contributions of property other than money.
Charitable contributions are deductible under section 170
only if verified under regulations prescribed by the Secretary.
Sec. 170(a)(1). Under the applicable regulations, contributions
of money made in taxable years beginning after December 31, 1982,
are required to be substantiated by one of the following: (1) A
canceled check; (2) a receipt from the donee charitable
organization showing the name of the donee, the date, and amount
of the contribution; or (3) in the absence of a canceled check or
receipt, other reliable written records showing the name of the
donee, the date, and amount of the contribution. Burrell v.
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