Thomas M. and Dolores F. Gomez - Page 9

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          if business related, were not included on his expense reports and            
          reimbursed by his employers.5                                                
               We conclude, therefore, that petitioners failed to satisfy              
          the requirements of sections 162 and 274.  Respondent's                      
          determination on this issue is sustained.                                    
          Issue 2. Charitable Contribution Deduction                                   
               Petitioners claimed total charitable contributions for 1993             
          in the amount of $26,086.  Of that amount, respondent allowed a              
          charitable contribution deduction of $1,300 and disallowed the               
               Subject to certain limitations,6 section 170(a) authorizes a            
          deduction for charitable contributions made to or for the use of             
          organizations described in section 170(c) within a taxable year.             
          However, a charitable contribution deduction is allowed only if              
          it is verified under regulations prescribed by the Secretary. See            
          sec. 170(a)(1).                                                              

               5Although petitioner testified that one of his employers                
          imposed a limit of $50,000 on the amount of expenses that would              
          be reimbursed, the total amount of expenses claimed did not                  
          exceed that limit even if such a limit did exist.  Petitioner did            
          not testify which employer imposed the limit, nor did he call a              
          representative of the employer as a witness.  Letters from the               
          employers, included as exhibits to the stipulation of facts, made            
          no reference to any limit on reimbursement.                                  
               6Sec. 170(b)(1)(A) provides, in pertinent part, that, in the            
          case of an individual, any charitable contribution to a church or            
          an educational organization meeting certain requirements shall be            
          allowed "to the extent that the aggregate of such contributions              
          does not exceed 50 percent of the taxpayer's contribution base               
          for the taxable year."  Sec. 170(b)(1)(F) defines the term                   
          "contribution base" to mean adjusted gross income (computed                  
          without regard to any net operating loss carryback to the taxable            
          year under sec. 172).                                                        
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