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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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