- 6 - 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. SeePage: Previous 1 2 3 4 5 6 7 8 Next
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