Robert and Clara Satriana - Page 6




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                    He said, That's what is allowable under the law.  I               
               know it.  I've studied the books.  I've been an IRS man.               
               I've done taxes for 17 years.  And I know what I'm doing.              

               With respect to the first issue, petitioners claimed                   
          charitable contribution deductions on their returns as follows:             

          1998       1999                                                             
               Cash (checks)                     $5,667     $5,584                    
               Noncash contributions                413        413                    
               Totals                          $6,080     $5,997                      

               At trial, Mrs. Satriana admitted that the bulk of their                
          contributions were noncash rather than cash.  She submitted lists           
          of clothing and other household items that she and her husband              
          donated to two organizations, which they estimated were worth               
          $5,000 and $3,800, respectively, for 1998 and 1999; however, no             
          appraisals were ever made of the value of the properties                    
          contributed, nor were any written acknowledgments of such                   
          donations made by the donee organizations.  Mrs. Satriana                   
          admitted that their cash contributions were far less than the               
          amounts claimed on their returns.  Neither of the tax returns               
          included an IRS Form 8283, Noncash Charitable Contributions,                
          which is required to satisfy the requirements of section 1.170A-            
          13(b)(3), Income Tax Regs., relating to deductions in excess of             
          $500 claimed for a charitable contribution of property other than           
          money.  The Court is satisfied that Mr. Beltran deliberately and            






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