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Commissioner, 40 T.C. 330, 340 (1963). Even though petitioner is
a pro se taxpayer, application of that rule in this case is
appropriate. The Court, during the trial, specifically advised
petitioner: “You can’t add any facts in the brief”, and “Any
facts that you want me to consider, you have to tell me right now
on the record.” Cf. Clifton-Bligh v. Commissioner, T.C. Memo.
2003-44. Moreover, by failing to state whether West Angeles
Church of God in Christ provided any goods or services in
consideration, in whole or in part, for what, on its face,
appears to be a contribution in excess of $250,4 the letter fails
to satisfy the substantiation requirements of section 170(f)(8).
See sec. 170(f)(8)(B)(ii).
We are satisfied that the 2000 Gospel Temple Baptist Church
receipt constitutes a “receipt” for the contributions listed
therein. See sec. 1.170A-13(a)(1)(ii), Income Tax Regs. It
fails to state, however, whether the church provided any goods or
services in consideration, in whole or in part, for those
contributions. Because the contribution for “Revival” and each
of the 12 monthly contributions are stated to be contributions of
$250 or more, all of those contributions fail to meet the
requirements of section 170(f)(8)(B)(ii). Therefore, they are
4 The West Angeles Church of God letter contains no
breakdown, by amount, of the $732 in total contributions for
2000. Therefore, it does not support a finding that all or any
portion of that contribution was in increments of less than $250.
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