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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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