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receipts, canceled checks, or other contemporaneous evidence that
could aid in the valuation of the contributed property.5
Accordingly, petitioners have not shown that they are entitled to
deductions greater than the amounts already claimed during the
1990 and 1991 tax years.
Next we consider whether petitioners may claim contributions
for unreimbursed expenses incurred by Omega in connection with
services performed by Omega employees for the benefit of CBR.
Petitioners contend that certain services performed by Omega
employees at the behest of petitioners and for the benefit of CBR
entitle petitioners to deduct as passthrough charitable
contributions the salaries paid in connection with services
performed. Respondent argues that petitioners are not entitled
to a deduction for the salaries paid to Omega employees for work
performed on the ranch because the work benefited Omega.
There are in dispute charitable “cash contributions”6 of
$121,149, $76,711, and $95,016 for the tax years 1993, 1994, and
1995, respectively. Aside from petitioner’s self-serving
testimony, petitioners submitted a schedule showing some of the
pay periods during the years in issue; however, the schedule is
5 Petitioners’ only receipt was for a mobile home with a
purchase date of June 13, 1983, at a price of $19,500. It is not
known whether this mobile home was an item contributed to
Christian Boys Ranch, Inc. (CBR).
6 In effect, these are gifts of services as opposed to cash
contributed to CBR.
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