Betty Kendrix - Page 14

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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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