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I just drop in the basket maybe somewhere between
$5 and $10 -- five and ten dollars -- and as far as
tithes, I don't faithfully put in 10 percent tithes
every pay period, I do put in 10 percent tithes. I
can't attest to how frequently I do it -- maybe every
month, every other pay period or so.
This testimony, however, does not justify the amounts that
petitioner claimed. Respondent acknowledges that the testimony
would support a deduction of $260 per year for contributions to
the church. We agree, and petitioner is entitled to a
contribution deduction of $260 in 1993. For 1994, petitioner is
entitled to a contribution deduction of $2,685 consisting of $260
contributed to the church, $1,300 contributed to the Combined
Federal Campaign, and $1,125 in other contributions reflected in
canceled checks that have been stipulated. Petitioner presented
no evidence of noncash contributions and cannot be allowed any
further deductions.
Petitioner contends that she mailed her returns for 1993 and
1994 on September 10, 1994, and August 10, 1995, respectively.
She states that she "can only speculate that her returns were
improperly credited under a previous name, mis-filed, or lost by
the IRS." In her posttrial memorandum, petitioner asserts for
the first time that the statute of limitations bars the notice
for 1993 and that, therefore, all issues for that year are
"moot". Her statute of limitations claim is not timely. See
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