Stanley Joseph Jennings - Page 5




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          American Gazette, the African American Magazine, and Take Pride!            
          Community newspaper to organizations (which are not identified in           
          the record) in Lima and Findlay, Ohio, in 1995.                             
          B.   Petitioner’s Income Tax Returns for 1994, 1995, and 1996               
               Petitioner called his local office of the Internal Revenue             
          Service (IRS) and spoke to Marlene A. Bunten (Bunten), an IRS               
          problem resolution officer, sometime between 1990 and 1995.                 
          Bunten told petitioner that he could deduct charitable                      
          contributions on Schedule A of his income tax returns, that                 
          instructions for claiming the deduction were in the booklet that            
          the IRS provides with his return, and that he would be required             
          to prove his contributions.  Petitioner told Bunten: “Well, I’m             
          going to try anyway and see what happens.”                                  
               On a date not specified in the record, petitioner wrote on a           
          3" by 3" paper “Tithes/(illegible word) $6074.00 1989 Tabernacle            
          of God” (the 3" by 3" paper).                                               
               Petitioner deducted the following amounts as charitable                
          contributions for 1994, 1995, and 1996:                                     
          Description                   1994      1995       1996                     
          Cash or check2                $2,860.00  $1,418.00  $8,011.62               
          Other than cash or check      0.00       0.00          0.00                 
          Carryover from prior year     34,100.30  23,610.40  24,510.70               
          Total charitable              36,960.30  25,028.40  32,522.32               
          contribution                                                                



               2  The Schedules A for the years in issue contain the phrase           
          “cash or check”.  However, none of petitioner’s contributions               
          were by check.                                                              





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