James R. and Janet M. Landrum - Page 21

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          comparing prices in classified ads, used furniture stores, and              
          the retail sales outlets of various charitable organizations.               
               While the preprinted forms appear authentic, we nevertheless           
          conclude that petitioners’ self-generated receipts and other                
          documents do not substantiate the deductions claimed in the                 
          instant case.  See Higbee v. Commissioner, supra.  We do not find           
          petitioners’ valuations reliable.  The value of an individual’s             
          used clothing and old furniture and furnishings, in questionable            
          condition, obviously is not the same as the retail asking price             
          or list price at a retail store, even a second-hand store.  Once            
          again we note that petitioners testified about their need for               
          funds.  Consequently, if they really had items worth many                   
          thousands of dollars, they might be expected to sell these items            
          and use the proceeds to satisfy their admitted financial needs.             
          They did not do so, but chose to give away the property in                  
          question without obtaining any sort of appraisal and claim                  
          substantial deductions.  Under these circumstances, we must                 
          conclude that petitioners have exaggerated the value of their               
          charitable contributions.  We hold that petitioners have failed             
          to introduce credible evidence to substantiate the actual items             
          contributed and their fair market values.  Accordingly,                     
          petitioners’ deductions for charitable contributions are limited            
          to the amounts allowed by respondent.                                       

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