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After concessions by both parties, the issues to be decided
are: (1) Whether petitioners are entitled to a deduction for
charitable contributions, (2) whether petitioners are entitled to
a deduction on Schedule A for miscellaneous business expenses,
(3) whether petitioners are entitled to a deduction under section
179, (4) whether petitioners are entitled to deductions for home
office expenses, and (5) whether petitioners are liable for the
accuracy-related penalty.
Some of the facts have been stipulated, and they are so
found. Petitioners resided in Canyon Lake, California, at the
time of the filing of their petition.
Charitable Contributions
Petitioners claimed a deduction for charitable contributions
for $3,312, consisting of cash gifts of $412 and $2,900 of gifts
other than cash or check. A Form 8283, Noncash Charitable
Contributions, was attached to the 1995 return and detailed
contributions of four separate groups of property items, the fair
market value of which allegedly totaled $2,900. Respondent
disallowed the entire claimed deduction. Petitioners now concede
that they are not entitled to the deduction for the noncash gifts
as set forth on Form 8283, while respondent concedes that
petitioners have substantiated $81 of cash gifts.
Petitioner Don Coffman (Mr. Coffman) testified that part of
the cash gifts consisted of his estimate of currency that
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