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Respondent has failed to establish that petitioner knew or
believed that her former spouse was not engaged in the farming
for profit. Accordingly, we hold petitioner is entitled to
relief under section 6015(c) from the tax liability arising out
of this activity.
V. Charitable Contributions
A. Background
On their 1987 return, petitioners claimed a charitable
contribution deduction of $5,556. Of this amount, $4,059 was
listed as contributed to “1st United Methodist”. In 1987,
petitioner wrote five checks to the St. Cloud First United
Methodist Church on the NCNB account totaling $5,500. Respondent
allowed the $5,556 charitable contribution deduction claimed on
the 1987 return.
On their 1988 return, petitioners claimed a charitable
contribution deduction of $8,165. On the attached Schedule A,
the claimed contribution was identified as “ERS-106, 1st United
Meth. 8,059". Respondent disallowed the entire amount claimed as
a charitable contribution deduction for 1988 on the ground that
petitioners had failed to substantiate the charitable
contribution. In 1988, neither petitioner nor Mr. Rowe wrote any
checks on the NCNB account to the St. Cloud First United
Methodist Church.
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