Braun Michael and Twanda B. Cameron - Page 8

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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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