Karen L. Thorpe - Page 12

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          schedules.  Finally, petitioner submitted a number of checkbooks            
          that contain carbon copies of some of the checks written during             
          the years 1993 and 1994.  We find that petitioner's summary                 
          schedules and check registers combined with carbon copies of a              
          number of the checks, qualify as reliable written records showing           
          the name of the donee, the date, and amount of the contribution.            
          Sec. 1.170A-13(a)(1), Income Tax Regs.  Therefore, petitioner is            
          entitled to deductions for cash contributions of $6,150, the                
          amount shown on her 1993 Schedule A.  Petitioner is also entitled           
          to a deduction of the full amount of cash contributions reported            
          on her Schedule A in 1994 in the amount of $6,313.                          
               With respect to contributions of property other than money,            
          petitioner offered a receipt from the AMVETS National Service               
          Foundation (AMVETS), dated April 1993, which lists various items            
          of property totaling $2,300.  Petitioner offered three other                
          receipts each listing various items of property given to the                
          Salvation Army all within the year 1993.  The three receipts from           
          the Salvation Army purport to assign a total value to the items             
          listed in each receipt of $1,480, $1,003, and $1,657.  Petitioner           
          did not deduct any of the amounts, which are listed on the AMVETS           
          or Salvation Army receipts, on her 1993 Federal income tax                  
          return.  Petitioner did not explain why she did not initially               
          deduct these amounts.  Moreover, petitioner testified that she              
          based the values assigned to the items on the AMVETS and                    





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