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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
balance.
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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