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2. Whether petitioner may deduct charitable contributions
claimed for expenditures made to his personal residence which
were allocable to space used exclusively by a section 501(c)(3)
organization named the Jan Stussy Foundation (Foundation). We
hold he may not.
3. Whether petitioner may deduct at the standard mileage
rate his automobile expenses connected to the determination of
his personal income tax liability. We hold he may.
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded.
FINDINGS OF FACT
Some facts were stipulated. The stipulated facts and the
accompanying exhibits are incorporated herein by this reference.
We find the stipulated facts accordingly. Petitioner resided in
Los Angeles, California, when his petition was filed.
During 1998, petitioner resided in a single family residence
(residence). The residence measured 2,085 square feet and was
titled in the name of the Stussy Family Trust (Trust).
Petitioner’s father, Jan Stussy (Dean Stussy), was the Trust’s
beneficial owner up until his death on July 31, 1990. Dean
Stussy was an active professional painter, and he was the Dean of
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