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in effect gifts. Sec. 170(c). Accordingly, petitioners are not
entitled to deduct $2,935 attributable to contributions made for
the maintenance of Ms. Perry in 1996.
The substantiation requirements are clear. We find
petitioners credible and believe that petitioners donated
furniture and clothing to the Purple Heart and Salvation Army in
1996. However, petitioners failed to substantiate the specific
amounts of the donated clothing and furniture. Therefore, we
find that for 1996 petitioners are entitled to deduct $25 for
each bag of clothing, totaling $450, and $100 for the furniture.
Petitioners failed to provide any substantiation for the
United Way donation, cash donations, and petitioner’s payroll
deduction in conjunction with the CFC. With regard to Mrs.
Cameron’s cash donation of $375, we believe that, on the basis of
their gross income, the $375 claimed for a cash deduction is not
unreasonable. Therefore, we will allow petitioners to deduct
this amount. Petitioners were afforded an opportunity to submit
the necessary documentation to substantiate the claimed
deductions for the United Way and the CFC; however, they failed
to do so. Accordingly, petitioners are not entitled to
deductions for the purported $1,190 United Way donation and
petitioner’s $120 payroll deduction in 1996.
Petitioners submitted an itemized list of additional
contributions made to various organizations (i.e., St. Jude
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