Regina B. Jackson - Page 6

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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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