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$1,709.03.5 She presented no evidence to substantiate the
amounts.
Petitioner claimed charitable contributions deductions in
the years at issue. For 1993, petitioner claimed a deduction for
contributions of $9,500 by cash or check and $500 by other than
cash or check. Respondent allowed $2,700 and disallowed the
remainder for lack of substantiation. For 1994, petitioner
claimed a deduction for contributions of $4,100 by cash or check
and $210 by other than cash or check. Respondent allowed $3,600
and disallowed the remainder. For 1995, petitioner claimed a
deduction for contributions of $5,280 by cash or check.
Respondent allowed $2,230 and disallowed the remainder.
Petitioner acknowledged that some of the donated items were to
individuals and not to recognized charitable organizations. For
example, petitioner donated a television to a handicapped child.
Other than her testimony, petitioner presented no evidence at
5 Petitioner’s list consisted of the following items:
Thermometer, digital, $9.19; fiber opticoloscope/opthalmoscope
set, $229.95; Beltone Audio Scout audiometer, $575 (with an “X”
next to this item on the list); scale, $30; hemoglobin
photometer, $600; hemoglobin curettes, $50; heavy duty tote-a-
chart carrier, $14.95; Uso sticks, $26.57; two blood pressure
kits, $150.59 each; cardiac stethoscope, $68.29; fan, $14;
completely stocked first aid kit, $59.95; clinic supplies, $75.
The list gives a total of $1,709.03, with an offset of $250
without explanation, for a net amount of $1,459.03. The Court
notes petitioner's figures do not add up correctly; see
discussion of the substantive issue, infra.
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