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intentionally listed petitioners' noncash charitable
contributions on the returns at less than $500 and inflated the
cash contributions to avoid the need for appraisals and written
acknowledgments from the donees. The Court holds that
petitioners are not entitled to any deductions for noncash
contributions for the 2 years at issue. As to cash
contributions, based on the record and in accordance with this
Court's discretionary authority under Cohan v. Commissioner, 39
F.2d 540, 543-544 (2d Cir. 1930), the Court allows petitioners
cash contribution deductions of $300 for each year at issue.
With respect to the second issue, relating to petitioners'
claim of an itemized deduction for unreimbursed employee expenses
for 1998, Mrs. Satriana claimed at trial that the amount at issue
represented expenses for the use of her vehicle in connection
with her Mary Kay Cosmetics activity. However, the record does
not reflect that Mrs. Satriana was engaged in this activity
during 1998. There was no Schedule C, Profit or Loss From
Business, included with the 1998 tax return relating to such an
activity, nor was there any income or deductions reported or
claimed on the return relating to such activity. Petitioners,
therefore, are not entitled to any expense deduction for the use
of a vehicle in connection with a nonexistent trade or business
activity during 1998. Mrs. Satriana also contended that the
vehicle was used by Mr. Satriana in connection with his
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