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by Mr. Rowe. Petitioner credibly testified that she was not
surprised by the amounts of charitable contributions deductions
claimed in 1988 and 1989, and she believed that contributions
were made during those years.
Respondent maintains that if only petitioner wrote checks to
the church from the joint account in 1987, then the fact that no
checks were written to the church from the joint account in 1988
demonstrates that petitioner had actual knowledge that no
contributions were made in either 1988 or 1989.27 However,
petitioner testified that, beginning in 1988, her role in paying
bills and writing checks diminished because Mr. Rowe began to
take over those duties. Mr. Rowe corroborated this point by
testifying that at some point during the years in issue he took
over the responsibility of paying certain bills, such as mortgage
payments, car payments, and credit card payments. Mr. Rowe
further testified that he had various other accounts which he
used to transfer money and that petitioner did not have knowledge
of these accounts.
The fact that no checks were written on petitioners’ joint
account in 1988 does not establish that petitioner had actual
knowledge that no contributions were made to the church in either
1988 and 1989. Mr. Rowe testified that he did not know whether
27As previously mentioned, no evidence was presented
establishing whether any checks were written on the NCNB account
to the St. Cloud First United Methodist Church in 1989.
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