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Petitioners also claimed, on their 1999 return, a deduction
of $2,400 for cash donations under section 170. Petitioners
claimed this consisted of cash donations made to various
churches, Mrs. Booker’s mother, and street beggars. When
questioned about written substantiation, Mr. Booker responded:
“I just made a rough estimate.” Any money petitioners gave to
street beggars, sometimes referred to as “pan handlers”, or to
relatives for their support is not deductible under section 170
as charitable contributions. Sec. 170(c). Petitioners did not
substantiate the amount of their other contributions, nor did
they establish that the organizations they contributed to were
qualified organizations. The deduction of $2,400 in cash
contributions claimed by petitioners is, therefore, disallowed.
With respect to the year 2000, petitioners also presented
filled-in receipts from various charitable organizations listing
donations received. At trial, however, Mrs. Booker testified
that the lists did not represent items actually donated in 2000,
but was “Not 2000. Just--that was a list--he [Mr. Booker] has
the forms for the year 2000. I just made that list up * * *. I
just made a list of items in which we have replaced over a period
of time.” Mrs. Booker then testified she was sure she had
donated a copier and computer during 2000 but offered no proof of
such donations. In addition, petitioners offered no evidence as
to the cash donations claimed on their 2000 return. Due to the
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