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the use of an organization described in section 170(c) and
verified as required by the statute and corresponding
regulations. As one example of the requisite verification,
contributions of $250 or more are disallowed unless the taxpayer
substantiates the donation with a contemporaneous written
acknowledgment by the donee. Sec. 170(f)(8).
Here, only with respect to the American Heart Association
expenditure did petitioners offer a statement in compliance with
section 170(f)(8), and respondent properly allowed a deduction to
the extent supported by that document. No basis for any greater
deduction has been suggested.
Concerning the other deductions, the record not only reveals
problems under section 170(f)(8) but also raises additional
issues. Nothing establishes that any were made to qualified
donees. The $5,000 payment to the Republican Party was
apparently conceded, and political contributions are generally
disallowed in any event. Cloud v. Commissioner, 97 T.C. 613,
628-629 (1991). Finally, the Court is not satisfied that the
payments to New Arizona Family and the Phoenix Zoo in fact
represented contributions and not some form of entertainment
expenditure subject to section 274.
L. Promotion or Marketing
There are two other expenditures, one of which actually
consists of two separate charges, that petitioners deducted under
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